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 paper examines five problematic areas of the Life Insurance Company Income Tax Act of 1959 including the 10-for-1 rule, the deduction for investment income on qualified pension and profit-sharing plans, limitations on certain deductions, policyholder surplus account and shareholders surplus account. A discussion of the paper follows. From Transactions of Society of Actuaries 1976, Vol. 28.