Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: Letter from the Editor

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

Description: This article discusses IRS Notice 2016-32.

Description: Update on tax reform

Description: This is a letter to the editor regarding the October 2014 Taxing Times supplement on the Camp proposals on the taxation of life insurance companies.

Description: A summary of a recent U.S. District Court decision regarding the applicability of the Federal Excise Tax (FET) on foreign-to-foreign retrocessions.

Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: Sequel to the author's paper The Taxation of Insurance in Canada, which was published in 1970 in Volume XXII of the Transactions. The first paper covered the history of insurance taxation in Canada through 1969, including a description of the radical changes that became effective that year as an early phase of tax reform, following the 1967 recommendations of the Royal Commission on Taxation. Further general tax reforms became effective in 1972, including the introduction of taxes on capital gains a number of clarifications and refinements were also enacted in 1973. The present paper outlines these general changes, with particular emphasis on their effect on insurance. Finally, a completely revised mathematical presentation of the taxation of insurance corporations is given, together with formulas and examples of the marginal taxation rates on various kinds of income and disbursement of such corporations. Followed by discussion papers submitted by 2 authors