Description: Consideration of the deterministic gross premium reserve component of PBR

Description: We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of tax reserves computed precisely according to the requirements of the Internal Revenue Code, and the IRS has challenged the reserve deduction. Other sections of this article also cover IRS rulings on the treatment and valuation of an insurance company stock purchased as an asset acquisition and COLI life insurance.

Description: A continuation of the conversation about principle-based reserves (PBR). Actuaries and an attorney discuss revisit federal-income tax-related issues as they relate to PBR.

Description: A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts.

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: A discussion of the effective dates and statutory reserves cap for variable annuities under Actuarial Guideline 43.

Description: This column will discuss the taxation of the issuer with respect to a failed contract.

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: Prevailing Standard Mortality and Morbidity Tables May Be Adjustable for Tax Reserves

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.