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: Update on accounting and capital/RBC issues subsequent to tax reform.

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: Update on tax reform

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 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: This article describes how there are many kinds of plans and arrangements under which qualified annuities are issued, and the rules governing them differ considerably.

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 article outlines the IRS directive published in July 2014, which provides a safe harbor treatment for variable annuity hedging gains and losses relating to VA contracts issued before Dec. 31, 2009.