Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

Description: A discussion of the ramifications, facts and rules associated with loss reserves and underwriting reserves that are held by foreign subsidiaries for life insurance and annuity contracts.

Description: In TAM 201149021, the Internal Revenue Service (the “Service”) National Office has ruled that an insurance contract that insures against a decline in market value of assets leased to third parties is not an insurance contract for federal income tax purposes.

Description: This article is a companion to “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change,” an article written by John T. Adney and Craig R. Springfield (May 2012 Taxing Times Supplement) that describes the various material change rules found in the Code, highlighting the complexities insurers face in navigating through these rules when a life insurance contract is materially changed. The Adney and Springfield article also addresses the difficulties in interpreting the tax law requirements under the various effective date rules contained in the Code sections affecting life insurance contracts.

Description: An extensive look at Actuarial Guideline 38, "The Application of the Valuation of Life Insurance Policies Model Regulation."

Description: Discussion of the March 1, 2013 Internal Revenue Service (“IRS”) release of PLR 201309011, which addresses the application of the section 817(h) diversification requirements to variable contracts that have invested in illiquid investment vehicles (the “Funds”).

Description: Tax code tidbits

Description: After the bid process, desk review, rebate reallocation, an “enjoyable” audit, and open enrollment; the Medicare plan year starts. Throughout the year, organizations find it pertinent to get an accurate picture of their Part D liability as reinsurance, LICS (Low Income Cost-Sharing) subsidy, and risk corridors are accrued. Attendees will learn about the basics of Part D accruals, how future accrual amounts are estimated based on patterns in the data, and how bid assumptions versus actual results impact plan sponsor profitability. We will also discuss financial statement treatment of these items. Real-life examples from bids to outcomes will be provided to enhance the discussion. Ultimately, attendees will come away with a deeper understanding how their bid assumptions play out, and how they can use Part D accruals to plan for future bid development.

Description: Discusses the reasons for changing emphasis on reserve strengthening programs and looks at methods adopted to emphasize the reserve character of undistributed surplus.

Description: This paper presents multiple book reviews: Reports from Staff of U.S. House of Representatives Committee on Ways and Means and U.S. Senate Committee on Finance, Reports in Connection with Social Security Legislation 1975-77, 'Statement on Cost Comparisons of Individual Life Insurance Policies', by Canadian Institute of Actuaries, 'Investment Activities of Life Insurance Companies' from Huebner Foundation Lectures, 'The Life Insurance Industry's Marketing Dilemma' by Johns, 'The Future of Social Security' by Munnell, 'Social Security - Today and Tomorrow' by Ball, 'Mortality Table Construction' by Batten, 'Mortality Table Construction' by Batten, 'The Crisis in Social Security - Problems and Prospects' by Boskin, 'A History of Interest Rates' by Homer, 'Indexation of Pensions and Other Benefits' by Robert Myers, 'Life Insurance Accounting' by Strain, '1978 Annual Report of the Board of Trustees of the Federal Hospital Insurance Trust Fund...' by US Congress. Brief summaries of additional readings are also included.