Description: This dialogue discusses the history and purpose of section 811(a) and its historic role in the computation of life insurance company taxable income and, in particular, reserves.

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 different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: Update on accounting and capital/RBC issues subsequent to tax reform.

Description: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: This article describes how there are many kinds of plans and arrangements under which qualified annuities are issued, and the rules governing them differ considerably.