Description: High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in reserving methodology or assumptions will be subject to the “10-year-spread” requirements of section 807f of the Internal Revenue Code. This article discusses possible answers.

Description: Statutory Statement of Accounting Principle SSAP No. 35 prescribes accounting for guarantee fund assessments and potential future premium tax credits against these assessments. This article discusses the deductibility of these assessments for federal income tax purposes, providing updates on recent court cases and regulatory guidance.

Description: This article details proposed regulations issued by the IRS that clarify that a single series may be treated as an entity separate from a series organization for federal income tax purposes, even if it is not recognized as a separate entity under local law.

Description: Discusses of the application of disproportionate asset acquisition rules under the life/nonlife regulations. How the amount of premiums or reserves should be measured is also discussed in detail.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: This article discusses the Section 338h10 election on the disposition of an insurance company.