Description: In this session, panel members speculate about changes to insurance company taxation, policyholder taxation and insurance product taxation in the 1980's. Both U.S. and Canadian viewpoints are shared.

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.

Description: This paper was written to demonstrate that universal life and indeterminate premium products are similar to participating plans. Followed by several discussion papers submitted.

Description: On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine in Webber v. Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets supporting a variable life insurance contract purchased through a private placement transaction. In the end, however, the Webber court leaves a lot of questions unanswered—most significantly, the elusive answer to how to define investor control. This article examines the Investor Control Doctrine, as explained and applied by the U.S. Tax Court in Webber, and considers some of the open questions that remain after June 30, 2015.

Description: Read the June 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Primer on the federal income taxation of nonqualified annuities

Description: This presentation is a concurrent session from the 1991 Meeting of the Society of Actuaries, held April 18-19 in New Orleans. In this life insurance product tax session, attorneys representing the American Council of Life Insurance ACLI, the Internal revenue Service, ‘IRS,’ and the law firm of Davis & Harman discuss the status of recent IRS Private Letter Rulings, current activities of the American Council of Life Insurance, ‘ACLI,’ and other topics including the international reach of Internal Revenue Code sections 7702 and 7702A. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 1.

Description: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.

Description: Article from The Actuary September 1989 – Volume 23, No. 8 discusses TAMRA: the U.S. Technical and Miscellaneous Revenue Act of 1988.

Description: October issue of Taxing Times