Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: An overall analysis and attribution analysis of the impacts of the 2017 Tax Cuts and Jobs Act for certain life insurance contracts.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Changes to AG 43 and what that might mean for tax purposes. Also, summary of IRS Notice 2016-63 (provides safe harbor tax guidance on use of 2017 CSO tables).

Description: The article describes changes to the computation of tax reserves as a result of the Tax Cuts and Jobs Act.

Description: A change in the way in which statutory life insurance and annuity reserves are determined in the United States is heading toward adoption. Currently, the Actuarial Opinion and Memorandum Regulation AOMR combines formulaic factor-based minimum reserves with reserve adequacy testing. The American Academy of Actuaries Academy is working with the National Association of Insurance Commissioners NAIC to finalize the basic framework of a principles-based reserve PBR methodology, based on a gross premium valuation, for life insurance products. The NAIC Life and Health Actuarial Task Force LHATF has also been considering Actuarial Guideline VACARVM that would introduce a PBR method for the valuation of variable annuity contracts.

Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

Description: This article discusses tax and accounting issues that arise under a recently-issued Chief Counsel Advice in which the IRS applied a life insurance company tax rule to a nonlife company that issues life insurance products

Description: T3: TAXING TIMES TIDBITS