Description: This paper was written to demonstrate that universal life and indeterminate premium products are similar to participating plans. Followed by several discussion papers submitted.

Description: Read the June 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: The Chairperson of the Taxation Section discusses how the section will deal with changes to the US Tax Code.

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.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. In this session dealing with life insurance company federal income tax, the panelists discuss the impact of the so-called deferred acquisition cost [DAC] or proxy DAC tax created by the Omnibus Budget Reconciliation Act [OBRA] of 1990. Topics include stock versus mutual company reactions and response, the impact on mergers and acquisitions, reinsurance, and consolidation, product changes, small company problems and opportunities, new categories of specified insurance contracts, and the impact on Canadian companies. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 4B.

Description: This article discusses the June 23, 1977 Supreme Court ruling that a life insurance company must include the net valuation portion but not the associated loading of deferred and uncollected premiums in its assets and gross premium income as well as in its reserves in computing its tax liability. Some companies have been using this procedure or a modification of it for the past few years. Other companies have been filing returns conforming to IRS regulations which required including gross deferred and uncollected premiums. These companies may need to file amended returns for open tax years if they paid taxes not due or understated usable operations/loss carry forwards. The author then goes on to review the implications of the court’s decision for companies filing amended returns.

Description: This discussion looked at defining tax parity between mutual companies and stock companies as well as the consequences of failure to achieve tax parity.

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

Description: This presentation is a concurrent session from the 1991 Meeting of the Society of Actuaries, held April 18-19 in New Orleans. The panelists discuss issues related to capitalization of policy acquisition expense, the so-called “DAC Tax,” from the Omnibus Budget Reconciliation Act of 1990, including provisions of the act and reinsurance questions. Latest developments in other company tax areas are covered, including court cases, regulatory matters, and audit issues. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 1.