Description: One major feature of the OECD's two-pillar regime is that MNEs would base the calculation of taxes due on book-based financial statements. The article provides a summary of how these rules operate along with suggested actions insurers can take today to prepare for timely compliance.

Description: This article briefly summarizes the history of the Passive Foreign Investment Company (PFIC) tax regime. Then it provides a detailed description of the PFIC proposed regulations issued in July of 2019.

Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.

Description: A summary and analysis of REG-103163-18, the proposed regulations providing guidance for property-casualty loss reserve discounting (LRD) under IRC Section 846.

Description: Taxing Times -- Volume 11, Issue 2, June 2015

Description: Synopsis of Issue Brief prepared by Tax Work Group of the Academy-LTD Claim Reserve Assumption Basis: Use of date of incurral/date of issue of original policy.

Description: This article discusses the Section 338h10 election on the disposition of an insurance company.

Description: May 2015 marked the inaugural issue of Taxing Times, the newsletter of the newly-formed Taxation Section of the Society of Actuaries. In the spring of 2015, we recognize this milestone with a trip down memory lane.

Description: Frequently Asked Questions on tax reserve methods and assumptions, based on law in effect prior to 12/31/2017.