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: Read the June 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Read the February 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. In this session dealing with life insurance company federal income tax, the panelists discuss the impact of the so-called deferred acquisition cost [DAC] or proxy DAC tax created by the Omnibus Budget Reconciliation Act [OBRA] of 1990. Topics include stock versus mutual company reactions and response, the impact on mergers and acquisitions, reinsurance, and consolidation, product changes, small company problems and opportunities, new categories of specified insurance contracts, and the impact on Canadian companies. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 4B.

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: This is a discussion about 1959 Act dealing with federal income tax on life insurance companies. Specific topics include: A. Impact the new tax law has had on: i the investment policies of individual companies, ii company accounting systems and procedures, iii actuarial bases for new contracts? B. What principles have been followed in allocating the federal income tax among the annual statement lines of business? How is the assessment to a line of business with a loss from operations established? Is the tax on the interest on surplus allocated on some general basis or with regard to the relative contributions of the different lines to the accumulated surplus? C. How is the tax taken into account in asset share tests and dividend scale determinations?

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: The purpose of this paper is to set forth a mathematical technique which in the author's experience has proved useful in testing the tax implications of various management actions.

Description: This paper examined two interrelated aspects of federal income taxation of life insurance companies. First, a common-sense approach to the Life Insurance Company Income Tax Act of 1959 was developed. Second, marginal tax rates for Phase III companies was developed.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.