Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: The Chairperson of the Taxation Section discusses how the section will deal with changes to the US Tax Code.

Description: The article describes changes to the computation of discounted unpaid losses (claim reserves) as a result of the 2017 tax legislation.

Description: This dialogue discusses the history and purpose of section 811(a) and its historic role in the computation of life insurance company taxable income and, in particular, reserves.

Description: This article describes how there are many kinds of plans and arrangements under which qualified annuities are issued, and the rules governing them differ considerably.

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: Discusses of the application of disproportionate asset acquisition rules under the life/nonlife regulations. How the amount of premiums or reserves should be measured is also discussed in detail.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are required in different states.