Description: Various insurer corporate tax issues are discussed as well as some court cases involving insurer taxes, including the recent USAA Life case involving preliminary term reserves on universal life business. First part of two-part Session 6 of the 1991 Valuation Actuary Symposium. See 'The New DAC Tax' for second part with presentations by Sikora or Eldridge.

Description: This discussion at the SOA 1990 San Francisco Spring Meeting covers alternative minimum tax including deferred acquisition costs, investment planning and new legislative proposals.

Description: This session from the 1995 SOA Boston Meeting reviews recent U.S. regulatory and tax developments, U.S. product taxation issues including corporate-owned life insurance COLI and certificate of deposit CD annuities and a summary of recent Canadian income tax developments. From the Record of the Society of Actuaries, Vol. 21, No. 4b.

Description: This paper develops an analytical method for evaluating the utility of tax-planning activities that cause initial statutory surplus strain and expands the horizon beyond normal pricing applications to the evaluation of other activities requiring the initial investment of statutory surplus.

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: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: This paper will provide demonstrations of the following three statements: That the calculation of principles-based reserves should ignore federal income taxes That the currently required statutory deferred tax calculation would need to be changed to permit an appropriate deferred tax asset to accompany such reserve so that the result can be correctly principles-based on a post-tax basis That the Tax DAC, pursuant to Section 848 of the Internal Revenue Code, is effectively a negative tax reserve.

Description: This article discusses IRS Notice 2016-32.

Description: Internal Revenue Code (I.R.C.) §§243–2461 provide that a corporation is allowed a percentage deduction for dividends received from other corporations (the DRD). In addition to the general corporate rules regarding the DRD, if the recipient of a corporate dividend is a life insurance company, I.R.C. §812(a) further allocates the benefit of the DRD between the company’s share and the policyholders’ share. This allocation methodology is often referred to as proration. Proration has historically involved a complex and at times contentious2 formulaic process.

Description: A discussion of funding arrangements that can reduce the costs of providing medical coverage through lower reserves or state tax savings, instead of through cutting benefits.