Description: Discussion of private letter tax rulings on the definition of Cash Surrender Value for purposes of interpreting the definition of life insurance for the policyholder's taxation of the contracts.

Description: Presented at April 1986 Spring Meeting. Addresses whether the newly imposed defined benefit pension guidelines are actuarially sound, is the IRS properly equipped to administer the guidelines, what are the professional implications of not complying with the guidelines and how have differences been resolved.

Description: Topics include: 1. Formation of the American Academy of Actuaries and governance 2. Federal tax developments - discount on life insurance advance premiums, group term life, imputed income factors under individual policy pension trusts, estate tax effect of assignment of group life coverage 3. Newly created Servicemen's Group Life Insurance - plan summary.

Description: These are legal notes concerning policy owner federal income tax, taxation to an agent for expenses for sales convention travel, claims contest on a policy with false statements on the application, timing on surrender of a life insurance policy immediately before death, permitted investment by a life insurance company in a property/casualty company, extraterritorial issues pertaining to regulation of group life insurance, and tax deduction for reserves on pension contracts covering its own employees.

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

Description: Updated discussion of IRS Proposed Regulations under Section 162(m)(6), their potential impact upon the life insurance industry, and a 2 percent de minimis exception.

Description: The Chairperson of the Taxation Section discusses how the section will deal with changes to the US Tax Code.

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: As part of tax reform introduced effective at the beginning of 1988, a major revision of the taxation of life insurance companies operating in Canada occurred. This guide highlights specific legislation, discussion papers, policyholder taxation and history of such legislation.

Description: Presented at June 1986 Spring Meeting. This session discussion is about the impact of the Tax Equity and Fiscal Responsibility Act 'TEFRA', the Deficit Reduction Act 'DEFRA', and any new enacted or proposed revisions in the Internal Revenue Code on insurance company taxes, employee benefits and insurance products.