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: Primer on the federal income taxation of nonqualified annuities

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

Description: This article summarized the Administration's proposals for new tax revenues in 2010 with respect to insurance and offers the ACLI viewpoint.

Description: A discussion of the issues to be considered for computing tax reserves relating to guaranteed renewable and noncancellable health insurance and how these concerns are sometimes overlooked.

Description: The American Council of Life Insurers provides an update on recent tax-related ACLI activity. Topics in this issue include (1) the NAIC's Principle-Based Reserves (PBR) Review Working Group and its exposed revisions to the Annual Statement Blanks; (2) ongoing communications with the Internal Revenue Service and Treasury to seek published guidance on PBR; (3) an update on tax reform activity in Congress; (4) the framework for change issued by the NAIC's Variable Annuities Issues (E) Working Group; and (5) the ERISA Advisory Council's development of model notices and disclosures for pension risk transfers.

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: A discussion of Section 7702 and age 100 insured and the need for guidance on combined annuity and long-term care contracts

Description: This article discusses several issues related to the IRS and taxation. These include partial exchanges of non-qualified annuity contracts, Long Term Care features on Annuity or Life contracts, and the applicability of the Foreign Account Tax Compliance Act [FATCA] to Life Insurance Campanies and products.

Description: Chairperson column - update on section activity