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: The article provides guidlines for the proper way to correct several types of tax reserve errors.

Description: A discussion of: IRS requirement disclosures of uncertain tax positions, disallowed interest reductions on earnings and profits, and tax standards for partial worthlessness deductions.

Description: A discussion of, first, the three-year transition period for adopting principle-based reserves and how it might not apply to tax reserves, and second, the tax impact of adding investment options to in-force contracts.

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: The article suggests that the case of State Farm Mutual Automobile Ins. Co. v. Commissioner, 698 F.3d 357 (7th Cir. 2012), and INT 03-17 may support the argument that estimated extra-contractual obligations are deductible by life insurance companies

Description: Discussions on CIGNA, SEPP failure, investor control, tacking rule, and split-dollar life insurance arrangement are featured.

Description: The Internal Revenue Code Requires Companies to Use Statutory Reserve Assumptions for Tax Reserves (Except Where It Doesn’t)

Description: Tidbits include discussions about: Policy loans in excess of cost basis, treatment of loss adjustment expenses, LAE, for life insurance companies, and separate account investments in group trusts.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.