Description: Two relatively recent developments have heightened tax managers’ anxiety concerning the possible disclosure of tax accrual workpapers.

Description: At the beginning of this year, Representative Dave Camp (R-MI) retired from the House of Representatives after 12 terms, the last two terms serving as Chairman of the Committee on Ways and Means. Chairman Camp has played a central role in the national conversation on tax reform, primarily through a series of discussion drafts addressing international tax reform, financial products tax reform, small business tax reform and, most recently, a comprehensive tax reform discussion draft that we explored in a special edition of TAXING TIMES last fall. Kristin Norberg, TAXING TIMES editor, recently sat down with Chairman Camp to talk about his career in the House, the development of the Tax Reform Act of 2014, and some of its potential impacts on the insurance industry.

Description: This editorial highlights the hot topics happening in the tax industry today.

Description: Discusses proposed regulations regarding reserve deductions for certain captives under IRC Section 1502 related to consolidated group intercompany insurance transactions.

Description: A discussion of the Obama Administration’s fiscal year 2011 revenue proposals affecting life insurance companies and products.

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

Description: The Internal Revenue Service “the Service” or “IRS” recently released Technical Advice Memorandum 200939019 “the TAM”. The TAM initially caused a stir among some in the insurance tax industry because it disallows a tax deduction that was permitted on the NAIC Annual Statement hereinafter “NAIC statement”. Specifically, the TAM states that unpaid loss adjustment expenses “LAE” for retiree medical benefits may only be deducted in the tax year in which the benefits are included in income by the employee who earned the benefits, despite the fact the amounts were properly included on the NAIC statement and regardless of deductibility of the unpaid LAE under the Internal Revenue Code “the Code”. This article discusses the memorandum.

Description: This article details proposed regulations issued by the IRS that clarify that a single series may be treated as an entity separate from a series organization for federal income tax purposes, even if it is not recognized as a separate entity under local law.

Description: This article summarizes the government guidance for protected cells in the insurance context and the ABA Recommendation, and comments on the Notice and ABA Recommendation in light of traditional notions of equity ownership for federal corporate income tax purposes.

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.