Description: A summary of a recent U.S. District Court decision regarding the applicability of the Federal Excise Tax (FET) on foreign-to-foreign retrocessions.

Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.

Description: Discusses how companies must ensure that significant and necessary product development, and administrative and compliance system changes, have been completed and tested in time to accommodate new requirements.

Description: The financial crisis of the recent past has prompted the director of the financial services industry portion of the Large and Mid-Size Business “LMSB” Division of the Internal Revenue Service “Service” to announce an increased focus during audit on the reporting by members of the financial services industry of losses attributable to bad debts or to worthless securities issued by subsidiaries.

Description: T3: TAXING TIMES TIDBITS

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.

Description: High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in reserving methodology or assumptions will be subject to the “10-year-spread” requirements of section 807f of the Internal Revenue Code. This article discusses possible answers.