Description: Full version of Taxing Times, February 2007, Volume 3, Issue No. 1.

Description: On March 25, 2010, the Treasury and IRS issued Notice 2010-29. The new Notice follows-up Notice 2008-18, in which the Treasury Department Treasury and the Internal Revenue Service IRS identified concerns regarding proposed Actuarial Guideline VACARVM and suggested approaches that might be taken to address those issues. Actuarial Guideline VACARVM was effective, as AG43, beginning on Dec. 31, 2009. This discussion is the fourth in a continuing series of interdisciplinary dialogues in TAXING TIMES on selected tax issues related to proposals regarding principle-based reserves.

Description: Discusses the problem with the computation of tax reserves for VA contracts with Guaranteed Living Benefit riders that were issued prior to December 31, 2009.

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: The recent Tax Technical Corrections Act of 2007, Pub. L. 110-172, signed into law on Dec. 29, 2007, includes a provision that permits a taxpayer to select positions in a straddle and thereby avoid surprise applications of the straddle rules by the IRS on audit.

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

Description: Comparison of statutory and tax accounting rules in treatment of non-performing assets.

Description: Discussions on: 1. tax deductability of surrender losses of life insurance contracts 2. the IRS questioning of the immediate drop in asset values for variable product valuations 3. the analysis of risk distribution in the context of reinsurance and 4. Life Company Net Operating Loss NOL Carryback.

Description: A roundtable discussion of the new international accounting standards and the possible implications for all insurers.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).