Description: I.R.C. § 4371 imposes an excise tax on policies issued by foreign insurers or reinsurers covering U.S. risks. The application of the tax to funds withheld reinsurance can raise difficult questions. The IRS’s position is that an accrual concept applies, although that position is questionable. Taxpayers that instead determine the excise tax by looking only to actual payments made by the ceding company to the reinsurer or to the net amount of the ceded premiums after adjusting for the allowance paid by the reinsurer have a variety of arguments to support their position. The language of the premium excise tax, the regulations thereunder, the legislative history of the provision, and the very nature of an excise tax all support the position that the tax applies only when there is an actual payment. Other Code provisions that use similar language as well as the Supreme Court also support this view.

Description: This article addresses the scope of reserve valuation rules that compute or estimate reserves “on the basis of recognized mortality or morbidity tables, and assumed rates of interest.”

Description: Read the June 2018 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: Read the June 2016 issue of Taxing Times.

Description: Full version of Taxing Times, December 2005, Volume 1, Issue No. 1.

Description: This update column from ACLI the “General Explanations of the Administration’s Revenue Proposals for Fiscal Year 2022” (Green Book).

Description: Read the February 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: May 2013 issue of TAXING TIMES, the newsletter of the Taxation Section

Description: May 2009 issue of the Taxation Section newsletter, Taxing Times