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: One of the significant tax benefits of a life insurance contract is that, for purposes of determining the taxable amount of proceeds received under the contract on distributions or surrender,the investment in the contract includes the aggregate amount of premiums, unreduced by the cost of insurance provided IRC section 72c. IRS rules net surrender value reserves must be reduced by a YRT reserve credit.

Description: Taxing Times, September 2006, Volume 2, Issue No. 2.

Description: Company Tax Issues

Description: Discussions on: 1. tax deductability of surrender losses of life insurance contracts 2. the IRS questioning of the immediate drop in asset values for variable product valuations 3. the analysis of risk distribution in the context of reinsurance and 4. Life Company Net Operating Loss NOL Carryback.

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: The article suggests that the case of State Farm Mutual Automobile Ins. Co. v. Commissioner, 698 F.3d 357 (7th Cir. 2012), and INT 03-17 may support the argument that estimated extra-contractual obligations are deductible by life insurance companies

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Prevailing Standard Mortality and Morbidity Tables May Be Adjustable for Tax Reserves

Description: A discussion of the issues to be considered for computing tax reserves relating to guaranteed renewable and noncancellable health insurance and how these concerns are sometimes overlooked.