Description: Discusses how companies must ensure that significant and necessary product development, and administrative and compliance system changes, have been completed and tested in time to accommodate new requirements.

Description: Changes to AG 43 and what that might mean for tax purposes. Also, summary of IRS Notice 2016-63 (provides safe harbor tax guidance on use of 2017 CSO tables).

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.

Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: Panelists discuss: [1] the tax implication of NAIC changes to reserving requirements, [2] the new NAIC Valuation of Life Insurance Policies Model Regulation [Reg. XXX], [3] Actuarial Guideline 33 [AG 33], [4] AG 34, and [5] highlights of an actual IRS audit involving these NAIC actuarial guidelines and regulations. From the 1997 Record of Society of Actuaries, Vol. 23, No. 3.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

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.

Description: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

Description: Author discusses the treatment of current life insurance reserves under the tax code in determining a life insurer's taxable income, and what challenges are ahead in the era of principles-based reserves.

Description: Section 818c of the Life Insurance Company Income Tax Act of 1959 provides, for companies holding other than net level premium reserves, a choice of two methods: exact revaluation or approximate revaluation to this basis. This paper discusses the impact of the choice on the level of a company's tax reserves. A discussion paper follows.