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: 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: On June 26, 2013, the Supreme Court released its decision in the case of United States v. Windsor, Executor of the Estate of Spyer, et al. addressing the constitutionality of the federal Defense of Marriage Act (“DOMA”). This article explores the implications for life insurance and annuity contract spousal provisions that are governed by federal law.

Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

Description: Updated discussion of IRS Proposed Regulations under Section 162(m)(6), their potential impact upon the life insurance industry, and a 2 percent de minimis exception.

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.

Description: Primer on the federal income taxation of nonqualified annuities

Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements