Description: This paper describes the Federal Income Tax FIT treatment of reserves historically. Then it describes Principles-Based Reserves PBR. Finally, it discusses issues in the treatment of PBR under FIT.

Description: A change in the way in which statutory life insurance and annuity reserves are determined in the United States is heading toward adoption. Currently, the Actuarial Opinion and Memorandum Regulation AOMR combines formulaic factor-based minimum reserves with reserve adequacy testing. The American Academy of Actuaries Academy is working with the National Association of Insurance Commissioners NAIC to finalize the basic framework of a principles-based reserve PBR methodology, based on a gross premium valuation, for life insurance products. The NAIC Life and Health Actuarial Task Force LHATF has also been considering Actuarial Guideline VACARVM that would introduce a PBR method for the valuation of variable annuity contracts.

Description: A discussion of: the value of a life insurance contract distributed from a qualified pension plan, IRS industry director directive on the DRD for life insurance separate accounts and IRS actuaries raising new issues on AG 34 tax reserves.

Description: This article is a companion to “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change,” an article written by John T. Adney and Craig R. Springfield (May 2012 Taxing Times Supplement) that describes the various material change rules found in the Code, highlighting the complexities insurers face in navigating through these rules when a life insurance contract is materially changed. The Adney and Springfield article also addresses the difficulties in interpreting the tax law requirements under the various effective date rules contained in the Code sections affecting life insurance contracts.