Description: This paper examined two interrelated aspects of federal income taxation of life insurance companies. First, a common-sense approach to the Life Insurance Company Income Tax Act of 1959 was developed. Second, marginal tax rates for Phase III companies was developed.

Description: The purpose of this paper is to set forth a mathematical technique which in the author's experience has proved useful in testing the tax implications of various management actions.

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: Discussion of private letter tax rulings on the definition of Cash Surrender Value for purposes of interpreting the definition of life insurance for the policyholder's taxation of the contracts.

Description: To most observers, the value of a life insurance contract is the cash surrender value. However, when it comes to life insurance and the Internal Revenue Code, things are seldom as simple as they appear on the surface.

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: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.

Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].

Description: Article Book Review by Ray in The Actuary, January 1979, Volume 13, Number 1