Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: This article describes the effect of different valuation interest rates and levels of surplus on income tax paid by life insurance companies via Phase 1 of the Federal Income Tax Act of 1959.

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.

Description: T3: TAXING TIMES TIDBITS

Description: The Revenue Act of 1987 amended section 807d2B of the Internal Revenue Code. It established the interest rate used in the calculation of tax reserves to be the greater of the applicable federal interest rate or the prevailing maximum statutory valuation rate for the contract’s calendar year of issue. The amendment is effective for contracts issued in tax years beginning after December 31, 1987. This document shows all the applicable federal interest rates from 1998 - 2009.

Description: One of the significant tax benefits of a life insurance contract is that, for purposes of determining the taxable amount of proceeds received under the contract on distributions or surrender,the investment in the contract includes the aggregate amount of premiums, unreduced by the cost of insurance provided IRC section 72c. IRS rules net surrender value reserves must be reduced by a YRT reserve credit.

Description: Recently, the IRS eliminated one of the more amorphous tax rules that at times was a stumbling block in Triple-X securitization transactions. Unfortunately, however, the IRS left an equally amorphous consolidated return rule untouched.

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: This article discusses XXX reserve financing, one of the most common life insurance industry capital markets funding transactions.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).