Description: This session discussion is about Federal Income Tax, policy issues, single premium products, inside buildup and corporate owned life insurance. From Record of the Society of Actuaries Vol. 15, No. 2.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: The Phase 3 tax is the description given to the federal income tax imputable to amounts withdrawn from the Policyholders Surplus Account maintained under the federal income tax law. This article discusses certain facets of the federal income Phase 3 tax as it relates to these withdrawals. Still significant for a large health insurer that has been in existence since before 1984 should health care become nationalized.

Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: On Nov. 2, 2018, the Internal Revenue Service (IRS) released Technical Advice Memorandum 201844009 (the TAM).

Description: This is a discussion about 1959 Act dealing with federal income tax on life insurance companies. Specific topics include: A. Impact the new tax law has had on: i the investment policies of individual companies, ii company accounting systems and procedures, iii actuarial bases for new contracts? B. What principles have been followed in allocating the federal income tax among the annual statement lines of business? How is the assessment to a line of business with a loss from operations established? Is the tax on the interest on surplus allocated on some general basis or with regard to the relative contributions of the different lines to the accumulated surplus? C. How is the tax taken into account in asset share tests and dividend scale determinations?

Description: 1992 SOA Annual Meeting, Washington, D.C. This session reviewed IRS rulings, regulations and announcements pertaining to pensions which were issued in 1991-1992. Specific areas addressed included: 1. Distribution tables. 2. Non-discrimination regulations. 3. Determination of highly compensated employees. 4. Determination letter program. 5. Rollovers. 6. Distributions. 7. Cash balance plans. 8. New directions in the examination program.

Description: The Chairperson of the Taxation Section shares the section council's plans and goals for 2017

Description: In session 75 PD of the New York Annual Meeting panelists explore practical considerations of maintaining compliance with federal income tax definition of life insurance rules. From the Record of the Society of Actuaries, Vol. 24, No. 3.

Description: Discussion of recent developments in the taxation of noncoordinated benefits such as fixed indemnity, hospital indemnity, and specified disease insurance policies. Developments include a recent Chief Counsel Advice Memorandum and proposed triagency rulemaking that would impact non coordinated benefits.