Description: Sequel to the author's paper The Taxation of Insurance in Canada, which was published in 1970 in Volume XXII of the Transactions. The first paper covered the history of insurance taxation in Canada through 1969, including a description of the radical changes that became effective that year as an early phase of tax reform, following the 1967 recommendations of the Royal Commission on Taxation. Further general tax reforms became effective in 1972, including the introduction of taxes on capital gains a number of clarifications and refinements were also enacted in 1973. The present paper outlines these general changes, with particular emphasis on their effect on insurance. Finally, a completely revised mathematical presentation of the taxation of insurance corporations is given, together with formulas and examples of the marginal taxation rates on various kinds of income and disbursement of such corporations. Followed by discussion papers submitted by 2 authors

Description: This session discussion is about current developments in the legislative situation and proposed changes, continuing unresolved audit issues, emerging issues of 1984 and later audits, policyholder taxation issues and alternate minimum tax AMT. From Record of the Society of Actuaries Vol. 15, No. 2.

Description: Highlights of recent American Council of Life Insurers (ACLI) activities

Description: Highlights of recent activities of the Taxation Section

Description: This session from the 1984 SOA Atlanta Meeting covers pending tax legislation with respect to life insurance companies, policyholder taxation and the current legislative outlook.

Description: Read the February 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: 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: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

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