Description: The financial crisis of the recent past has prompted the director of the financial services industry portion of the Large and Mid-Size Business “LMSB” Division of the Internal Revenue Service “Service” to announce an increased focus during audit on the reporting by members of the financial services industry of losses attributable to bad debts or to worthless securities issued by subsidiaries.

Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.

Description: This is a perspective of the upcoming year from the view of the Chair of the Council of the TaxationSection. Following the challenges from the past year and since the arrival of the pandemic, I discussed how we will adapt to this new virtual or hybrid world and how the Taxation Section will continue to offer material to its members.

Description: This update column from ACLI addresses the 2020 year-end spending and relief package with specific emphasis on its effect on the life insurance industry

Description: T3: TAXING TIMES TIDBITS

Description: In order to encourage health insurance issuers to offer health insurance coverage on the Exchange and on the individual and small group markets, while ameliorating the potential impact on any particular health insurance issuer of providing coverage without pricing for pre-existing conditions or the gender of the insured, the Affordable Care Act includes three risk-sharing programs: the Transitional Reinsurance program, the Risk Corridor program and the Risk Adjustment program (collectively referred to as the “3Rs”). The financial and tax reporting of each health insurance issuer is affected by the implementation of these risk-sharing programs because each health insurance issuer is required to pay for the programs’ costs, and some issuers are or will be eligible for benefits under them.

Description: Full version of Taxing Times, September 2007, Volume 3, Issue No. 3.

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: Tells what occurred after the adverse private letter ruling PLR 200738016 up to the issuance of the revenue procedure, and offers some speculation about the future.

Description: This article begins with a brief review of the general requirements of section 7702A and the consequences of MEC status for a life insurance contract and continues with a description of the evolution of the inadvertent MEC correction procedures over the past near decade.