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: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

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 column summarizes tax and retirement matters that ACLI and its member companies have been actively addressing. These include IRS 2015-2016 priority guidance items, the Department of Labor proposed fiduciary rule, proposed IRS hedge fund reinsurance rules, and new IRS notional principal contract rules.

Description: This article is a companion to “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change,” an article written by John T. Adney and Craig R. Springfield (May 2012 Taxing Times Supplement) that describes the various material change rules found in the Code, highlighting the complexities insurers face in navigating through these rules when a life insurance contract is materially changed. The Adney and Springfield article also addresses the difficulties in interpreting the tax law requirements under the various effective date rules contained in the Code sections affecting life insurance contracts.

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

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: This article discusses Internal Revue Code, ‘IRC,’ Sections 7702 and 7702A with respect to the implementation of the 2001 CSO Mortality Table, which must be used in the calculations for policies issued on or after January 1, 2006. “The insurance industry has requested guidance from the Treasury Department and the Internal Revenue Service on the proper application of the current computational rules to the 2001 CSO Mortality Table but, to date, such guidance has not been provided. Therefore, the Taxation Section established the 2001 CSO Maturity Age Task Force, the members of which authored this article, to propose methodologies that would be actuarially acceptable under Sections 7702 and 7702A of the Code for calculations under contracts that do not provide for actual maturity before age 100.” This article summarizes the task force recommendations.