Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.

Description: Updates on partial annuitization and exhanges, prevailing CSO valuation mortality tables, disclosure of offshore accounts through FATCA.

Description: A summary and analysis of REG-103163-18, the proposed regulations providing guidance for property-casualty loss reserve discounting (LRD) under IRC Section 846.

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 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: 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 article discusses the June 23, 1977 Supreme Court ruling that a life insurance company must include the net valuation portion but not the associated loading of deferred and uncollected premiums in its assets and gross premium income as well as in its reserves in computing its tax liability. Some companies have been using this procedure or a modification of it for the past few years. Other companies have been filing returns conforming to IRS regulations which required including gross deferred and uncollected premiums. These companies may need to file amended returns for open tax years if they paid taxes not due or understated usable operations/loss carry forwards. The author then goes on to review the implications of the court’s decision for companies filing amended returns.

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.