Description: A discussion of the ramifications, facts and rules associated with loss reserves and underwriting reserves that are held by foreign subsidiaries for life insurance and annuity contracts.

Description: In TAM 201149021, the Internal Revenue Service (the “Service”) National Office has ruled that an insurance contract that insures against a decline in market value of assets leased to third parties is not an insurance contract for federal income tax purposes.

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

Description: T3: TAXING TIMES TIDBITS

Description: In order to encourage health insurance issuers to offer health insurance coverage on the Exchange and on the individual and small group markets, while ameliorating the potential impact on any particular health insurance issuer of providing coverage without pricing for pre-existing conditions or the gender of the insured, the Affordable Care Act includes three risk-sharing programs: the Transitional Reinsurance program, the Risk Corridor program and the Risk Adjustment program (collectively referred to as the “3Rs”). The financial and tax reporting of each health insurance issuer is affected by the implementation of these risk-sharing programs because each health insurance issuer is required to pay for the programs’ costs, and some issuers are or will be eligible for benefits under them.

Description: This article discusses the complexities of such a simple statement as well as highlight certain differences between tax and book treatment of that capitalization.

Description: Update on accounting and capital/RBC issues subsequent to tax reform.

Description: We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of tax reserves computed precisely according to the requirements of the Internal Revenue Code, and the IRS has challenged the reserve deduction. Other sections of this article also cover IRS rulings on the treatment and valuation of an insurance company stock purchased as an asset acquisition and COLI life insurance.

Description: A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts.