Description: A discussion of the three private letter rulings addressing the tax treatment of group insurance contingent annuity contracts providing guaranteed minimum withdrawal benefits linked to an investment account released by the Internal Revenue Service.

Description: An explanation of the reasons why the IRS should rule on the application of section 351 to the transfer of assets and reserves in an indemnity coinsurance transaction where the ceding company transfers more assets to the assuming company than it would in an arms-length transaction and, therefore, the ceding company actually receives or is deemed to receive stock in the exchange for the transferred assets including the value of insurance in force. We also will summarize other interesting rulings in the PLR.

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: This paper was written to demonstrate that universal life and indeterminate premium products are similar to participating plans. Followed by several discussion papers submitted.

Description: Primer on the federal income taxation of nonqualified annuities

Description: In the environment of discussions about simplifying the tax code for individuals including eliminating many deductions, this editorial raises the question of the appropriateness of eliminating some of the tax benefits of employer benefit plans.

Description: After the 1986 tax-reform legislation, SPWL currently enjoys a tax treatment preferential to many other financial products. The author suggests that this distinction may not last long.

Description: The Required Minimum Distribution [RMD] Working Group of the SOA Taxation Section has completed research identifying considerations for actuaries and annuity insurers in determing the actuarial present value of additional benefits for computing the RMD under a deferred annuity contract. This is the Appendix I spreadsheet for determining the Actuarial Present Value of an annuitization bonus. Please see the SOA website research for the full report and other associated spreadsheets.

Description: U.S. corporate federal income taxation of life insurance companies underwent a major revision several years ago with the adoption of the 1984 Tax Act, following two years of stopgap taxation under TEFRA '1982 Tax Act'. This paper highlights the SOA study notes, a text of the IASA and other documents that provide a comprehensive introduction to life insurance company taxation.

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.