Description: Recognition of out-going and incoming council membership.

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: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

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: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.