Description: Tax considerations in structuring and pricing long-term care transactions. Includes consideration around the form of reinsurance and the unified loss rules applicable to stock transactions where they is a bargain purchase (also known as a tax basis step-down)

Description: On Nov. 2, 2018, the Internal Revenue Service (IRS) released Technical Advice Memorandum 201844009 (the TAM).

Description: This article, another in the popular series devoted to tax basics, provides an overview of how the Employee Retirement Income Security Act of 1974 (ERISA), the law governing employment-based retirement and health plans, impacts the use of annuities in pension and 401(k) plans. The article explains which types of plans are subject to ERISA, and which are not; why the concept of "plan assets" is critical; what duties an insurance company or distributor might take on when an annuity is placed with a retirement plan; and finally what disclosures may be required. The article also includes a brief introduction to terminal funding annuities. This article is intended for those with no prior experience in ERISA. Because the vast majority of retirement assets are saved originally in employment based plans like pension and 401(k) plans, understanding the basics of ERISA is important for anyone who will have a career in annuities and life insurance.

Description: Read the June 2019 issue of Taxing Times, published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: View full issue of Volume 15 Issue 1 of Taxing Time.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

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.

Description: Read the October 2019 issue of Taxing Times, published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: SOA Taxation Section membership trends and 2018 Survey Results

Description: A summary and analysis of REG-103163-18, the proposed regulations providing guidance for property-casualty loss reserve discounting (LRD) under IRC Section 846.