Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

Description: A discussion of the tax-related initiatives listed on the IRS Priority Business Plan for 2010 targeting product tax issues and how they relate to the work of the Taxation Section.

Description: A discussion of the many developments affecting taxation of life insurance companies and products.

Description: This article details proposed regulations issued by the IRS that clarify that a single series may be treated as an entity separate from a series organization for federal income tax purposes, even if it is not recognized as a separate entity under local law.

Description: Discusses the IASB insurance contract project and the major components of the new accounting standard, including the guidance it provides regarding how to define the term “insurance contract.”

Description: Discusses of the application of disproportionate asset acquisition rules under the life/nonlife regulations. How the amount of premiums or reserves should be measured is also discussed in detail.

Description: A discussion of the bill that will require tax reporting of sales of interests in life insurance policies. This bill will require the buyer of an interest in a life insurance policy to report the sale to the Internal Revenue Service and notify the life insurer that issued the policy.

Description: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: Taxing Time October 2012 issue

Description: The article discusses court decisions on the tax basis and taxable gain in life insurance contracts.