Description: This article discusses the guidance provided in IRS Notice 2022-6 and prior guidance on whether distributions from an individual account under a qualified retirement plan satisfy the exception to the 10 percent additional tax in Internal Revenue Code section 72(t) for certain substantially equal periodic payments.

Description: This article summarizes IRS guidance on what constitutes a change in basis for computing life insurance reserves under the Internal Revenue Code.

Description: This article provides a basic introduction to the taxation of qualified annuities held in qualified retirement plans and IRAs. The article has been updated for the SECURE Act and the SECURE 2.0 Act. The article describes the basic types of employer-based plans, provides of overview of the taxation of contributions and benefits when annuities are held in connection with plans and IRAs, explains the required minimum distribution rules, and offers a brief introduction to recent legislation impacting qualified annuities.

Description: TAXING TIMES recently sat down with a group of retired tax actuaries to hear about how they got involved in actuarial tax matters and how their tax experience impacted their careers. Their insights will be useful for actuaries who are just starting out in the profession, as well as more seasoned actuaries.

Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: A comprehensive look at Actuarial Guideline 43 VA CARVM. This article examines the statutory and tax implications of AG 43 for the determination of reserves for annuity writers.

Description: February 2010 Supplement to the Taxation Section newsletter, Taxing Times. Extensive discussion of the issues in computing statutory and tax reserves for annuities under VA CARVM.

Description: This article considers PLR 201304003, which addressed the application of Internal Revenue Code section 1035 to the exchange of a survivorship, or “second-to-die,” life insurance contract after the death of one of the insureds for a new life insurance contract covering only the life of the surviving insured.

Description: The article discusses recently-issued regulations under section 807 of the Internal Revenue Code, concerning the computation and reporting of reserves. The provisions addressed generally relate to the Tax Cuts and Jobs Act of 2017.

Description: The article provides an introduction to tax accounting for U.S. life insurance companies, with a focus on NAIC statutory accounting concepts. The author discusses permanent and temporary differences, the current tax provision, and deferred tax accounting requirements, including admissibility testing under SSAP No. 101.