Description: Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are required in different states.

Description: An extensive look at Actuarial Guideline 38, "The Application of the Valuation of Life Insurance Policies Model Regulation."

Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: This article discusses the important lessons for insurance companies that participate in drafting settlement agreements designed to achieve favorable tax treatment of the settlement payments.

Description: This article is a companion to “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change,” an article written by John T. Adney and Craig R. Springfield (May 2012 Taxing Times Supplement) that describes the various material change rules found in the Code, highlighting the complexities insurers face in navigating through these rules when a life insurance contract is materially changed. The Adney and Springfield article also addresses the difficulties in interpreting the tax law requirements under the various effective date rules contained in the Code sections affecting life insurance contracts.

Description: The article describes changes to the computation of tax reserves as a result of the Tax Cuts and Jobs Act.

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 dialogue discusses the history and purpose of section 811(a) and its historic role in the computation of life insurance company taxable income and, in particular, reserves.

Description: Two relatively recent developments have heightened tax managers’ anxiety concerning the possible disclosure of tax accrual workpapers.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.