Description: This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing tax reserves for pre-2018 tax years for annuity contracts subject to AG43 and VM-21 and life insurance contracts subject to VM-20 Principal Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain spread amounts in some cases to future tax years starting in 2018.

Description: Last March, Congress passed and the President signed the Patient Protection and Affordable Care Act followed by the Health Care and Education Reconciliation Act, which amended the former collectively, the “Act”. The article provides a brief background on the passage of the Act generally and the creation of the new Investment Income Tax in particular compares the existing provisions of the HI tax with the newly enacted provisions, and it then analyzes the import of the Investment Income Tax for annuities and, possibly, life insurance contracts. The article concludes with thoughts on the potential effect of the new tax on the annuity marketplace.

Description: Discussions on: 1. tax deductability of surrender losses of life insurance contracts 2. the IRS questioning of the immediate drop in asset values for variable product valuations 3. the analysis of risk distribution in the context of reinsurance and 4. Life Company Net Operating Loss NOL Carryback.

Description: Illustrates the lack of clarity about how the various grandfather clauses applicable to life insurance contracts should be applied in practice.

Description: The Internal Revenue Service “the Service” or “IRS” recently released Technical Advice Memorandum 200939019 “the TAM”. The TAM initially caused a stir among some in the insurance tax industry because it disallows a tax deduction that was permitted on the NAIC Annual Statement hereinafter “NAIC statement”. Specifically, the TAM states that unpaid loss adjustment expenses “LAE” for retiree medical benefits may only be deducted in the tax year in which the benefits are included in income by the employee who earned the benefits, despite the fact the amounts were properly included on the NAIC statement and regardless of deductibility of the unpaid LAE under the Internal Revenue Code “the Code”. This article discusses the memorandum.

Description: This article discusses XXX reserve financing, one of the most common life insurance industry capital markets funding transactions.

Description: Chairperson's column for the October 2020 issue of Taxing Times with thoughts on the effects of COVID-19 on the Taxation Section.

Description: A discussion of the Treasury’s Priority Guidance Plan for the year July 2010 through June 2011.

Description: An update from the ACLI staff to keep readers informed about the organization's work on tax issues affecting the life insurance industry.

Description: A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts.