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

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.

Description: Summary of Administration's FY 2023 Tax Proposals of Interest to Life Insurers

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine in Webber v. Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets supporting a variable life insurance contract purchased through a private placement transaction. In the end, however, the Webber court leaves a lot of questions unanswered—most significantly, the elusive answer to how to define investor control. This article examines the Investor Control Doctrine, as explained and applied by the U.S. Tax Court in Webber, and considers some of the open questions that remain after June 30, 2015.

Description: The article describes the IRS Industry Issue Resolution (IIR) process as applied to the Insurance Industry's Bad Debt Issue. The article describes the IRR process in general, how that process was applied to the bad debt issue, and the safe harbor approach available for insurance companies. The safe harbor is described in LB&I Commissioner Heather Maloy's Directive dated July 30, 2012 (LB&I-4-0712-009).

Description: In Schaeffler v. United States, the United States Court of Appeals for the Second Circuit issued a taxpayer-friendly decision on the scope of the attorney-client privilege and the work-product doctrine. The article explores the case and its meaning for the two doctrines, and specifically how it differs from the decision in United States v. Textron in the First Circuit.

Description: Complete issue of the October 2014 Taxing Times newsletter.

Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.