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: With the growth in SOA podcasts over recent years, here’s your chance to be part of the “live studio audience” for an upcoming podcast release. Inspired by The Social and The View, join us in our talk show setting as we discuss current and emerging topics in the actuarial profession, with incoming SOA President Andy Rallis as one of the many guests we’ll bring to the stage just after Tuesday’s Presidential Luncheon. This rapid-fire session will incorporate audience participation, opportunities to be part of the podcast during question-and-answer sessions and highlight new SOA section, research and education activities. Stay tuned after the meeting to listen in to the session through SOA podcast feeds.

Description: This article summarizes IRS guidance on what constitutes a change in basis for computing life insurance reserves under the Internal Revenue Code.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

Description: In February 2015, the Internal Revenue Service Chief Counsel appointed Alexis MacIvor as the chief of Branch 4 of the Office of the Associate Chief Counsel (Financial Institutions & Products). That branch (sometimes referred to by our readers as the “Insurance Branch”) has seven attorneys who work exclusively on issues concerning the taxation of insurance companies and the products those companies issue. Because of the importance of that branch’s work product to the issues that life actuaries must address every day, the Taxing Times Editorial Board and the Taxation Section Council thought our readers would appreciate the opportunity to meet Alexis and welcome her to the insurance tax actuarial community. Mark Smith of our editorial board recently met with Ms. MacIvor to talk about her background and her new role.

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.