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: Consideration of the deterministic gross premium reserve component of PBR

Description: Article discusses recent changes in the IRS LB&I Division's examination practices and approach that may affect the work-flow of company actuaries and may present opportunities to resolve tax issues for companies

Description: An update from the ACLI staff to keep readers informed about the organization's work on tax issues affecting the life insurance industry.

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.

Description: Discusses Schedule UTP, “Uncertain Tax Positions,” issued by the IRS, in detail.

Description: A look at the IRS initiative, the Industry Issue Resolution IIR Program, and its requested use to address the tax treatment of hedges of VA contract guarantees. The IIR Program is designed to address tax issues that are common to many business taxpayers and are frequently disputed.

Description: This article discusses the important lessons for insurance companies that participate in drafting settlement agreements designed to achieve favorable tax treatment of the settlement payments.