Description: The rules governing the tax treatment of distributions from life insurance or annuity contracts are complex. Worse, the relevant IRC section, section 72, seems at times to be the product of a conspiracy in restraint of understanding.

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: 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.