Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

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

Description: Insurance companies will be required to file the Internal Revenue Service IRS Schedule M-3 for tax years ending on or after Dec. 31, 2006. Schedule M-3 was designed by the IRS as a replacement for the Schedule M-1, which is used to reconcile a corporation's financial accounting income or loss with its taxable income or loss.

Description: Statutory Statement of Accounting Principle SSAP No. 35 prescribes accounting for guarantee fund assessments and potential future premium tax credits against these assessments. This article discusses the deductibility of these assessments for federal income tax purposes, providing updates on recent court cases and regulatory guidance.

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: 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.

Description: A brief discussion of the articles included in the February 2013 issue of Taxing Times.

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: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.