Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

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: 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: Kory J. Olsen, Taxation Section chair, interviewed Walter Welsh, focusing on the ACLI, retirement issues, and insurance regulation.

Description: Discusses five subjects, including proposed IASB discussion paper, split-dollar life insurance, penalties for paid tax preparers, statutory reserves for insurers, and NAIC securitization initiatives.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: May 2009 issue of the Taxation Section newsletter, Taxing Times

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: February 2010 Supplement to the Taxation Section newsletter, Taxing Times. Extensive discussion of the issues in computing statutory and tax reserves for annuities under VA CARVM.

Description: SSAP 10R supersedes Statement of Statutory Accounting Principles No. 10, Income Taxes “SSAP 10” and the new provisions set forth in this accounting principle are effective for year-end 2009 statutory financial statements. If elected, they provide, where appropriate, the ability to admit additional DTAs by increasing the projected realization period from one to three years along with increasing the statutory surplus limitation from 10 percent to 15 percent, provided the entity exceeds certain risk based capital “RBC” thresholds. SSAP 10R also makes explicit and gives definition to the implicit valuation allowance of SSAP 10, and increases transparency through its expanded disclosure requirements for all entities regardless of whether electing the expanded recognition provisions.