Description: Discussion of the March 1, 2013 Internal Revenue Service (“IRS”) release of PLR 201309011, which addresses the application of the section 817(h) diversification requirements to variable contracts that have invested in illiquid investment vehicles (the “Funds”).

Description: Presented at April 1985 Spring Meeting. Discusses: Futures, Options, Floating rate securities, Oil and Gas, Real Estate, Leased equipment, Joint ventures, Stripped securities, Zero coupon bonds, Mortgage pools, Sales - leasebacks.

Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

Description: The article describes the IRS Industry Issue Resolution (IIR) process as applied to the Insurance Industry's Bad Debt Issue. The article describes the IRR process in general, how that process was applied to the bad debt issue, and the safe harbor approach available for insurance companies. The safe harbor is described in LB&I Commissioner Heather Maloy's Directive dated July 30, 2012 (LB&I-4-0712-009).

Description: This paper describes a streamlined procedure for allocating investment income which permits the application of a single current investment-year interest rate, together with an averaged rollover rate, to an adjusted asset base to give essentially the same results as the traditional investment-year method. It also includes a discussion of the paper. From Transactions of Society of Actuaries 1976, Vol. 28.

Description: The principal purpose of this paper is to examine some of the factors that must be considered if the concept of investment generations is applied to the distribution of investment income within individual life insurance lines of business. It also includes a discussion of the paper. From Transactions of Society of Actuaries 1977, Vol. 29.

Description: This discussion covered: 1. The extent to which companies' net earned interest rates have risen above their low points from that of several years ago and 2. The NAICs' new method of dividing amortizable bonds into two classes in the valuation of securities

Description: A discussion of topics in a series of roundtable education sessions on life insurance products and companies at the collaborative meeting of the ACLI and member companies.

Description: This article briefly summarizes the history of the Passive Foreign Investment Company (PFIC) tax regime. Then it provides a detailed description of the PFIC proposed regulations issued in July of 2019.

Description: This paper considers two principles which at present are given little weight in accounting for investments: 1. the reported earnings of a business entity should not change solely because an investment is sold at a capital gain or loss and the proceeds are reinvested, and 2. the accounting treatment of common stock investments should not vary according to the portion of the issuer's outstanding common stock which the investment represents. The implications of these principles are explored in accounting for bonds, stocks and business combinations. A discussion of this paper is included.