Description: Summary of Administration's FY 2023 Tax Proposals of Interest to Life Insurers

Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

Description: The Tidbit summarizes LTRs 201609008 and 201613016 and discusses the definition of insurance under the tax code in light of these new pieces of guidance from the IRS.

Description: In order to encourage health insurance issuers to offer health insurance coverage on the Exchange and on the individual and small group markets, while ameliorating the potential impact on any particular health insurance issuer of providing coverage without pricing for pre-existing conditions or the gender of the insured, the Affordable Care Act includes three risk-sharing programs: the Transitional Reinsurance program, the Risk Corridor program and the Risk Adjustment program (collectively referred to as the “3Rs”). The financial and tax reporting of each health insurance issuer is affected by the implementation of these risk-sharing programs because each health insurance issuer is required to pay for the programs’ costs, and some issuers are or will be eligible for benefits under them.

Description: This article summarizes a recent revenue ruling concerning the insurance company qualification of an affiliate that reinsures retiree health benefits under an arrangement entered into by a VEBA.

Description: Discusses taxation of derivatives, as changed for some types under Dodd-Frank and not changed for others.

Description: The article deals with the critique of a technical advice memorandum issued by the IRS. It basically states the author's opinion that, although the conclusion was correct, the reasoning given was inappropriate.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.