Description: A discussion of, first, the three-year transition period for adopting principle-based reserves and how it might not apply to tax reserves, and second, the tax impact of adding investment options to in-force contracts.

Description: A continuation of the conversation about principle-based reserves (PBR). Actuaries and an attorney discuss revisit federal-income tax-related issues as they relate to PBR.

Description: Reserves for Annuity Contracts that Flunk Section 72(s) Can be Deductible

Description: This article discusses key tax issues that exist under current law with respect to asset rebalancing and hedging transactions that an insurance company might undertake.

Description: This column will discuss the taxation of the issuer with respect to a failed contract.

Description: The Internal Revenue Code includes certain rules that apply when a taxpayer has a change in method of accounting. A special rule applies when a life insurance company changes its basis of computing reserves. The article discusses two recent court cases, Bosamia v. Commissioner and Capital One Financial Corp. v. Commissioner, that address change-in-method-of-accounting issues. The article examines whether and how the courts' conclusions in these two cases might apply to changes in basis of computing reserves to correct errors.

Description: High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in reserving methodology or assumptions will be subject to the “10-year-spread” requirements of section 807f of the Internal Revenue Code. This article discusses possible answers.

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: A discussion of: IRS requirement disclosures of uncertain tax positions, disallowed interest reductions on earnings and profits, and tax standards for partial worthlessness deductions.

Description: When a life insurance company changes its basis for computing tax reserves, a special 10-year spread rule found in section 807(f) of the Internal Revenue Code applies to the change. But, what happens if the statutory accounting for original issue discount (OID) or bond premium changes? A discussion follows.