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: 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: This panel discussion, which occurred at the October 1982 Society of Actuaries Annual meeting in Washington D.C., presented information related to 401k Plans. Topics discussed included: - Historical background - Current developments - Features of 401k plans - What are the issues/problems

Description: Presented at October 1985 Annual Meeting. Discusses current topics involving insurance companies, such as: Impact on product design, Allocation of capital and resources, Consolidation, Regulations, Company structure, Proposed or current legislative matters.

Description: From a session at a meeting of the Society of Actuaries held in San Diego, CA, June 22-23, 2000 This discussion reviews the need for and a process for remediation of errors made with respect to an inadvertent non-egregious failure to comply with the modified endowment contract rules under Internal Revenue Code Section 7702A.

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.

Description: This article discusses key tax issues that exist under current law with respect to asset rebalancing and hedging transactions that an insurance company might undertake.

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.