Description: This paper covers the 1969 amendments to the Income Tax Act of Canada, which radically altered the taxation of life insurance proceeds and life insurance companies. It also covers prior tax bases and the 1967 recommendations of the Royal Commission on Taxation upon which the 1969 amendments were based. Finally, it discusses the interrelationship of the taxation of the policyholders and the insurer, and it compares the tax treatment of stock vs. mutual companies, life and non-life insurers, and resident vs. non-resident business and insurers.

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.

Description: This is a discussion paper in response to Raymond L. Whaley's work entitled, 'The Taxation of Insurance in Canada.'

Description: Sequel to the author's paper The Taxation of Insurance in Canada, which was published in 1970 in Volume XXII of the Transactions. The first paper covered the history of insurance taxation in Canada through 1969, including a description of the radical changes that became effective that year as an early phase of tax reform, following the 1967 recommendations of the Royal Commission on Taxation. Further general tax reforms became effective in 1972, including the introduction of taxes on capital gains a number of clarifications and refinements were also enacted in 1973. The present paper outlines these general changes, with particular emphasis on their effect on insurance. Finally, a completely revised mathematical presentation of the taxation of insurance corporations is given, together with formulas and examples of the marginal taxation rates on various kinds of income and disbursement of such corporations. Followed by discussion papers submitted by 2 authors

Description: An extensive look at Actuarial Guideline 38, "The Application of the Valuation of Life Insurance Policies Model Regulation."

Description: This article discusses the important lessons for insurance companies that participate in drafting settlement agreements designed to achieve favorable tax treatment of the settlement payments.

Description: This paper examined two interrelated aspects of federal income taxation of life insurance companies. First, a common-sense approach to the Life Insurance Company Income Tax Act of 1959 was developed. Second, marginal tax rates for Phase III companies was developed.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

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: A change in the way in which statutory life insurance and annuity reserves are determined in the United States is heading toward adoption. Currently, the Actuarial Opinion and Memorandum Regulation AOMR combines formulaic factor-based minimum reserves with reserve adequacy testing. The American Academy of Actuaries Academy is working with the National Association of Insurance Commissioners NAIC to finalize the basic framework of a principles-based reserve PBR methodology, based on a gross premium valuation, for life insurance products. The NAIC Life and Health Actuarial Task Force LHATF has also been considering Actuarial Guideline VACARVM that would introduce a PBR method for the valuation of variable annuity contracts.