Description: This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk can be identified and assessed.

Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: Enacted pursuant to the 2017 Tax Cuts and Jobs Act (TCJA) , the base erosion and anti-abuse tax (BEAT) is one of the most dramatic changes to the U.S. international tax landscape in recent years. The BEAT is essentially a minimum tax which applies to certain large U.S. and foreign corporations with U.S. operations with average annual gross receipts of at least $500 million and a base erosion percentage of 3 percent or higher (with some exceptions).

Description: Tax considerations in structuring and pricing long-term care transactions. Includes consideration around the form of reinsurance and the unified loss rules applicable to stock transactions where they is a bargain purchase (also known as a tax basis step-down)

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.