Description: The article provides an introduction to tax accounting for U.S. life insurance companies, with a focus on NAIC statutory accounting concepts. The author discusses permanent and temporary differences, the current tax provision, and deferred tax accounting requirements, including admissibility testing under SSAP No. 101.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: After nearly a decade of work by ACLI and representatives of its member companies, the Society of Actuaries SOA, the American Academy of Actuaries Academy, and the NAIC’s Life and Health Actuarial Task Force LHATF, on Sept. 24, 2008, the NAIC adopted a new actuarial guideline for applying the method of computing statutory reserves for variable annuity contracts AG VACARVM.

Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk can be identified and assessed.

Description: This article provides the reader with some insights regarding tax planning under the new required methodology.

Description: A discussion of the effective dates and statutory reserves cap for variable annuities under Actuarial Guideline 43.