Description: After outlining some of the issues involved in the taxation of life insurance companies, this paper describes the tax consequences of various strategic courses of action by life insurance companies. From Transactions of Society of Actuaries 1981, Vol. 33.

Description: This presentation is a panel discussion from the 1991 Meeting of the Society of Actuaries, held June 3-5 in Colorado Springs. The panelists discuss the status of rules and regulations on nondiscrimination for pension plans, including the relevant subsections of the Internal Revenue Code, ‘IRC,’ sections 401 and 410, and proposed regulations. In general, to be nondiscriminatory, a plan may not unduly favor highly compensated employees. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 3A.

Description: Basic discussion of premiums paid, investment in the contract, and basis as used in IRC provisions applicable to life insurance and annuity contracts.

Description: This presentation is a concurrent session from the 1991 Meeting of the Society of Actuaries, held April 18-19 in New Orleans. In this life insurance product tax session, attorneys representing the American Council of Life Insurance ACLI, the Internal revenue Service, ‘IRS,’ and the law firm of Davis & Harman discuss the status of recent IRS Private Letter Rulings, current activities of the American Council of Life Insurance, ‘ACLI,’ and other topics including the international reach of Internal Revenue Code sections 7702 and 7702A. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 1.

Description: This article comments on a 1972 paper on the same subject by John Fraser, which made a very careful analysis of the relation between the current earnings rate and the taxable interest. The author builds on Fraser’s illustrative calculations, which showed clearly that there was an optimal spread between the current earnings rate and the assumed reserve interest rate to produce the maximum interest deduction, by including an analysis of the after-tax yield effect.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

Description: October issue of Taxing Times

Description: A discussion of the PLR that addresses a Wellness Rider that an affiliated group of life insurance companies proposed to offer only on a prospective basis with newly issued life insurance contracts.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. The panelists present the basics of nondiscrimination in pension plans, the provisions of the tax code designed to prevent benefits and contributions from being steered primarily to the higher paid participants in a plan. The panelists discuss the relevant sections of the Internal Revenue Code, including 401[a][4], 410[b], 401[I], 401[a][26], and the recently published regulations. From the Record of Society of Actuaries, Volume 17, No. 4B.

Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.