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: Discussion of the ways the volatility of the full funding limitation can be used as a consulting opportunity. Discussion of smoothing cash flow in the current regulatory environment and cash-flow forecasting in a volatile market.

Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

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: In this paper, the author presents the statutory and regulatory rationale for the Internal Revenue Service, ‘IRS,” position on integration. The author discusses the integration requirements under IRC Section 401a which must be met for a private pension plan to receive favorable tax treatment, including the prohibited discrimination requirement. From the 1982 Transactions Vol. 34.

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: 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).

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.