Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: Description of general tax consequences of purchasing an insurance company, either through buying the assets or buying the stock.

Description: The article provides a summary of the Taxation Session sponsored sessions at the Life and Annuity Symposium.

Description: Provides a few highlights of the rules set forth in the Proposed 965 Regulations and the impact such rules have on the determination of various aspects of the toll tax calculation.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Kory J. Olsen, Taxation Section chair, interviewed Walter Welsh, focusing on the ACLI, retirement issues, and insurance regulation.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: This article discusses new tax reporting requirements for transfers for value under section 6050Y. It also discusses changes to the transfer for value rule of section 101(a)(2) and (3), including the definition of a reportable policy sale.

Description: This article discusses XXX reserve financing, one of the most common life insurance industry capital markets funding transactions.