Description: The articles describes Revenue Procedure 2018-20, providing historical background as well as discussing the content of the new procedure.

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.

Description: This article presents a high-level overview of the Federal Income tax rules in section 382 regarding limitations on the use of losses after an ownership change takes place and summarizes problems and issues for the insurance industry in proposed regulations under section 382 as summarized in comments made by the industry and the ACLI

Description: This article discusses the June 23, 1977 Supreme Court ruling that a life insurance company must include the net valuation portion but not the associated loading of deferred and uncollected premiums in its assets and gross premium income as well as in its reserves in computing its tax liability. Some companies have been using this procedure or a modification of it for the past few years. Other companies have been filing returns conforming to IRS regulations which required including gross deferred and uncollected premiums. These companies may need to file amended returns for open tax years if they paid taxes not due or understated usable operations/loss carry forwards. The author then goes on to review the implications of the court’s decision for companies filing amended returns.

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 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: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.

Description: Updates on partial annuitization and exhanges, prevailing CSO valuation mortality tables, disclosure of offshore accounts through FATCA.

Description: A detailed discussion on Private Letter Ruling 20123009 which states that owners of life insurance contracts in some circumstances want to decrease their death benefits and that the decreases contemplated are not ones resulting from application of a formula or other provision set forth in the contracts.

Description: Overview of articles in the October 2013 issue of TAXING TIMES.