Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

Description: Discussion of the ways the volatility of the full funding limitation can be used as a consulting opportunity. Discussion of smoothing cash flow in the current regulatory environment and cash-flow forecasting in a volatile market.

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: Section 818c of the Life Insurance Company Income Tax Act of 1959 provides, for companies holding other than net level premium reserves, a choice of two methods: exact revaluation or approximate revaluation to this basis. This paper discusses the impact of the choice on the level of a company's tax reserves. A discussion paper follows.

Description: Presented at June 1985 Spring Meeting. Discusses tax changes, company impact including reserve issues, product impact, and reinsurance.

Description: In this paper, the author presents the statutory and regulatory rationale for the Internal Revenue Service, ‘IRS,” position on integration. The author discusses the integration requirements under IRC Section 401a which must be met for a private pension plan to receive favorable tax treatment, including the prohibited discrimination requirement. From the 1982 Transactions Vol. 34.

Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.