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: The basic thesis of this paper is that student capability to iNteract with new problems can be significantly increased by frequently exposing them to Written derivations, verbal-Intuitive justification of formulae and core sets of Comprehensive techniques by which to approach problems. Both instructor composition of problem resources for presentation and student practice of these problem resources can be achieved by semi-mechanical procedures accessible to everyone. For brevity we shall refer to this type of instruction by the acronym WINC. Presented at the 30th Actuarial Research Conference, August 17-19, 1995, Pennsylvania State University, Pennsylvania

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: The SOA president emphasizes the importance of actuaries maintaining their level of professionalism by always striving to inform and prepare the decision maker with all the possibilities, not just the quick answers or the minimum level of disclosure.

Description: In this article, the editor talks about the contents of this issue of the Risk Management Newsletter. Also mentioned are the three categories the newsletter tries to cover 1. Risk Identification, 2. Risk Response, and 3. Risk Culture & Disclosures.

Description: This brief article details my observations as a senior consultant for a leading actuarial consultancy across the Middle East and South Asia regarding ORSA. It highlights key challenges, potential solutions and describes the dichotomy of management and consultant paradigm.

Description: Overview of articles in the October 2013 issue of TAXING TIMES.

Description: Article on the need for continuing education for actuaries

Description: A discussion about the section’s accomplishments including research activities, professional development and benefits of being a member of the section.

Description: The article discusses court decisions on the tax basis and taxable gain in life insurance contracts.