Description: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.

Description: This discussion looked at defining tax parity between mutual companies and stock companies as well as the consequences of failure to achieve tax parity.

Description: A discussion of spousal provisions that are governed by federal income tax law, specifically the difference between some state laws and the Defense of Marriage Act DOMA.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

Description: At the beginning of this year, Representative Dave Camp (R-MI) retired from the House of Representatives after 12 terms, the last two terms serving as Chairman of the Committee on Ways and Means. Chairman Camp has played a central role in the national conversation on tax reform, primarily through a series of discussion drafts addressing international tax reform, financial products tax reform, small business tax reform and, most recently, a comprehensive tax reform discussion draft that we explored in a special edition of TAXING TIMES last fall. Kristin Norberg, TAXING TIMES editor, recently sat down with Chairman Camp to talk about his career in the House, the development of the Tax Reform Act of 2014, and some of its potential impacts on the insurance industry.

Description: Reviews Elmer R. Benedict's book entitled Protecting Retirement Against Inflation, which present a broad program for equitable sharing of the inflation burden. The kingpin is an income adjustment, utilizing income taxes, designed to restore the purchasing power of the retired, disabled and surviving spouses.

Description: A recent list of government publications announces the publication of a volume entitled Actuarial Values I: Valuation of Last Survivor Charitable Remainders-Part B-Two-Life Tables for Untirusts and Pooled Income Funds - Internal Revenue Service Publication 7233 11-71 available from the Superintendent of Documents, U. S. Government Printing Office, Washington, D. C. 20402 for $4.50. The article outlines the actuarial formulas used in determining the tables used by the IRS.

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”.