Description: The article deals with the critique of a technical advice memorandum issued by the IRS. It basically states the author's opinion that, although the conclusion was correct, the reasoning given was inappropriate.

Description: Three tax-related articles of interest to those associated with smaller insurance companies.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. In this session dealing with life insurance company federal income tax, the panelists discuss the impact of the so-called deferred acquisition cost [DAC] or proxy DAC tax created by the Omnibus Budget Reconciliation Act [OBRA] of 1990. Topics include stock versus mutual company reactions and response, the impact on mergers and acquisitions, reinsurance, and consolidation, product changes, small company problems and opportunities, new categories of specified insurance contracts, and the impact on Canadian companies. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 4B.

Description: This session discussion is about FAS 96, the timing and measurement of the deferred tax effects, alternative minimum tax considerations, worksheets versus models, small company effective tax rate, consolidation returns and incorporating future tax strategies. From Record of the Society of Actuaries Vol. 15, No. 2.

Description: Dialogue between Peter Winslow, a tax attorney, and Edward Robbins and Christian DesRochers, tax actuaries, on selected tax issues related to proposals to change statutory reserving from a formula-based methodology to a principles-based approach.

Description: This session from the 1995 SOA Boston Meeting reviews recent U.S. regulatory and tax developments, U.S. product taxation issues including corporate-owned life insurance COLI and certificate of deposit CD annuities and a summary of recent Canadian income tax developments. From the Record of the Society of Actuaries, Vol. 21, No. 4b.

Description: This article discusses the importance of refining projected tax cash flows when making actuarial projections. It addresses specifically operating loss deductions, net operating loss carrybacks and carryforwards, capital coss carrybacks and carryforwards, cost basis of invested assets, tax DAC, tax complications caused by reinsurance and deferred taxes.

Description: For actuarial projections to serve as the management tools that they are intended to be, the persons charged with making those projections need to consider whether the projection is sufficiently sophisticated so that it does not miss major items.It is important to consider the tax effect. This article covers several of the major tax issues that should be considered in any actuarial projection.

Description: Addresses the question: “If it is accepted that reserves should be pre-tax, why should required capital be post-tax?”

Description: This paper develops an analytical method for evaluating the utility of tax-planning activities that cause initial statutory surplus strain and expands the horizon beyond normal pricing applications to the evaluation of other activities requiring the initial investment of statutory surplus.