Description: Updated discussion of IRS Proposed Regulations under Section 162(m)(6), their potential impact upon the life insurance industry, and a 2 percent de minimis exception.

Description: Highlights of recent American Council of Life Insurers (ACLI) activities

Description: Highlights of recent activities of the Taxation Section

Description: A memorial for a great tax actuary and colleague, Ed Robbins

Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: The article discusses a recent IRS private ruling on the application of the investor control doctrine to a variable contract for which the insurer proposed to add a new investment option. The new option closely paralleled a mutual fund that was open to public investment, i.e., it appeared to be a "clone," but the new option was itself not available outside of the variable contract. The IRS ruled that the doctrine did not apply.

Description: Description of general tax consequences of purchasing an insurance company, either through buying the assets or buying the stock.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: This is an article about how to place value on an annuity benefit.

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.