Description: A discussion of: the value of a life insurance contract distributed from a qualified pension plan, IRS industry director directive on the DRD for life insurance separate accounts and IRS actuaries raising new issues on AG 34 tax reserves.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. In this session dealing with life insurance company federal income tax, the panelists discuss the impact of the so-called deferred acquisition cost [DAC] or proxy DAC tax created by the Omnibus Budget Reconciliation Act [OBRA] of 1990. Topics include stock versus mutual company reactions and response, the impact on mergers and acquisitions, reinsurance, and consolidation, product changes, small company problems and opportunities, new categories of specified insurance contracts, and the impact on Canadian companies. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 4B.

Description: This paper examines five problematic areas of the Life Insurance Company Income Tax Act of 1959 including the 10-for-1 rule, the deduction for investment income on qualified pension and profit-sharing plans, limitations on certain deductions, policyholder surplus account and shareholders surplus account. A discussion of the paper follows. From Transactions of Society of Actuaries 1976, Vol. 28.

Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: This session from the 1995 SOA Boston Meeting reviews recent U.S. regulatory and tax developments, U.S. product taxation issues including corporate-owned life insurance COLI and certificate of deposit CD annuities and a summary of recent Canadian income tax developments. From the Record of the Society of Actuaries, Vol. 21, No. 4b.

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: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: Overview of articles in the October 2013 issue of TAXING TIMES.

Description: This discussion looked at defining tax parity between mutual companies and stock companies as well as the consequences of failure to achieve tax parity.

Description: This is a discussion about 1959 Act dealing with federal income tax on life insurance companies. Specific topics include: A. Impact the new tax law has had on: i the investment policies of individual companies, ii company accounting systems and procedures, iii actuarial bases for new contracts? B. What principles have been followed in allocating the federal income tax among the annual statement lines of business? How is the assessment to a line of business with a loss from operations established? Is the tax on the interest on surplus allocated on some general basis or with regard to the relative contributions of the different lines to the accumulated surplus? C. How is the tax taken into account in asset share tests and dividend scale determinations?