Description: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: This dialogue discusses the history and purpose of section 811(a) and its historic role in the computation of life insurance company taxable income and, in particular, reserves.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

Description: Discusses the CCA 201939003 and the conclusions that were made and the impacts it has on a taxpayer's ability to make an election for determining the interest rate used to compute tax-deductible life insurance reserves.

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: This article discusses tax and accounting issues that arise under a recently-issued Chief Counsel Advice in which the IRS applied a life insurance company tax rule to a nonlife company that issues life insurance products

Description: This article summarizes a recent revenue ruling concerning the insurance company qualification of an affiliate that reinsures retiree health benefits under an arrangement entered into by a VEBA.