Description: This article discusses XXX reserve financing, one of the most common life insurance industry capital markets funding transactions.

Description: Discusses the CCA 201939003 and the conclusions that were made and the impacts it has on a taxpayer's ability to make an election for determining the interest rate used to compute tax-deductible life insurance reserves.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: The NAIC approved the 2012 Individual Annuity Reserve table as the standard for computing reserves for individual annuity contracts and developed a model law regulation for states to adopt. On February 17th, 2015, ACLI submitted a letter to Alexis MacIvor, Chief of the Insurance Branch in the IRS Office of Chief Counsel, notifying her that as of December 24, 2014, 26 states had approved the 2012 IAR Table as the reserve standard for immediate annuity contracts issued on or after January 1, 2015. The letter thus confirms that the 2012 IAR Table is the Prevailing Commissioners' Standard Table for purposes of computing life insurance reserves under section 807(d) of the Code for individual annuity contracts.

Description: Discusses how companies must ensure that significant and necessary product development, and administrative and compliance system changes, have been completed and tested in time to accommodate new requirements.

Description: Recently, the IRS eliminated one of the more amorphous tax rules that at times was a stumbling block in Triple-X securitization transactions. Unfortunately, however, the IRS left an equally amorphous consolidated return rule untouched.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: Dialogue between Peter Winslow, a tax attorney, and Edward Robbins and Christian DesRochers, tax actuaries, on selected tax issues related to proposals to change statutory reserving from a formula-based methodology to a principles-based approach.

Description: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.