Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.

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 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 look at the IRS initiative, the Industry Issue Resolution IIR Program, and its requested use to address the tax treatment of hedges of VA contract guarantees. The IIR Program is designed to address tax issues that are common to many business taxpayers and are frequently disputed.

Description: Basic discussion of premiums paid, investment in the contract, and basis as used in IRC provisions applicable to life insurance and annuity contracts.

Description: Report highlighting some income tax legislative and litigation issues for insurance companies in 1962

Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

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