Description: Enacted pursuant to the 2017 Tax Cuts and Jobs Act (TCJA) , the base erosion and anti-abuse tax (BEAT) is one of the most dramatic changes to the U.S. international tax landscape in recent years. The BEAT is essentially a minimum tax which applies to certain large U.S. and foreign corporations with U.S. operations with average annual gross receipts of at least $500 million and a base erosion percentage of 3 percent or higher (with some exceptions).

Description: Discusses the section 6694 tax return preparer penalty regime and examines how it might potentially apply to other professionals, such as actuaries, who assist those traditionally considered to be tax professionals.

Description: Year 2004 marked the first tax-filing year that certain corporate taxpayers were required to file the newly created IRS Schedule M-3–designed as a replacement for the Schedule M-1, which is used to reconcile a corporation's financial accounting income or loss with its taxable income or loss.

Description: This is a perspective of the upcoming year from the view of the Chair of the Council of the TaxationSection. Following the challenges from the past year and since the arrival of the pandemic, I discussed how we will adapt to this new virtual or hybrid world and how the Taxation Section will continue to offer material to its members.

Description: The Tidbit summarizes LTRs 201609008 and 201613016 and discusses the definition of insurance under the tax code in light of these new pieces of guidance from the IRS.

Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

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: Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are required in different states.

Description: This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk can be identified and assessed.

Description: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.