Description: Almost 65 years ago, the Supreme Court issued its opinion in Helvering v. Le Gierse, addressing when an arrangement should be recognized as involving “insurance” for federal income tax purposes. According to the Court, an “insurance risk” must be present, and for an insurance risk to exist, there must be “risk-shifting and risk distribution.”

Description: This panel at the SOA 1982 Orlando Spring Meeting discusses tax parity for individual life insurance companies and products. The focus is on some of the very basic issues of taxation as the industry begins planning for a longer range solution to the issues posed by the current tax structure.

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.

Description: In February 2015, the Internal Revenue Service Chief Counsel appointed Alexis MacIvor as the chief of Branch 4 of the Office of the Associate Chief Counsel (Financial Institutions & Products). That branch (sometimes referred to by our readers as the “Insurance Branch”) has seven attorneys who work exclusively on issues concerning the taxation of insurance companies and the products those companies issue. Because of the importance of that branch’s work product to the issues that life actuaries must address every day, the Taxing Times Editorial Board and the Taxation Section Council thought our readers would appreciate the opportunity to meet Alexis and welcome her to the insurance tax actuarial community. Mark Smith of our editorial board recently met with Ms. MacIvor to talk about her background and her new role.

Description: This presentation is a panel discussion from the 1991 Meeting of the Society of Actuaries, held June 3-5 in Colorado Springs. The panelists discuss the status of rules and regulations on nondiscrimination for pension plans, including the relevant subsections of the Internal Revenue Code, ‘IRC,’ sections 401 and 410, and proposed regulations. In general, to be nondiscriminatory, a plan may not unduly favor highly compensated employees. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 3A.

Description: 1992 SOA Annual Meeting, Washington, D.C. This session reviewed IRS rulings, regulations and announcements pertaining to pensions which were issued in 1991-1992. Specific areas addressed included: 1. Distribution tables. 2. Non-discrimination regulations. 3. Determination of highly compensated employees. 4. Determination letter program. 5. Rollovers. 6. Distributions. 7. Cash balance plans. 8. New directions in the examination program.