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: 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: 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.

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: This article describes the allocation of FATCA withholding risk in cross-border reinsurance arrangements and discusses practical considerations in regards to the drafting of those agreements.

Description: This article focuses on the TCJA’s changes to the provisions for net operating losses (“NOLs”) and highlights some of the challenges surrounding the NOL provisions that insurance companies may face when making business decisions around reinsurance agreements.