Description: This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing tax reserves for pre-2018 tax years for annuity contracts subject to AG43 and VM-21 and life insurance contracts subject to VM-20 Principal Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain spread amounts in some cases to future tax years starting in 2018.

Description: Chairperson's column for the October 2020 issue of Taxing Times with thoughts on the effects of COVID-19 on the Taxation Section.

Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

Description: Current tax issues affecting the insurance industry, including the Inflation Reduction Act (Budget Reconciliation Bill)'s tax provisions, including the corporate minimum book income tax and share repurchase (or stock buyback) excise tax; the tax treatment of non coordinated benefits (also known as fixed indemnity benefits); and an update on the OECD’s Base Erosion and Profit Shifting Project

Description: This article provides the reader with some insights regarding tax planning under the new required methodology.

Description: This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk can be identified and assessed.

Description: A discussion of the effective dates and statutory reserves cap for variable annuities under Actuarial Guideline 43.

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.

Description: This article discusses recent proposals made by the American Council of Life Insurers related to: life insurance reserves annuity reserves and risk-based capital risk-based capital for investments and accounting for Deferred Tax Assets.

Description: The Taxation Section chairperson talks about member benefits, CPD requirements, seminars, webinars and educational opportunities.