Description: We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of tax reserves computed precisely according to the requirements of the Internal Revenue Code, and the IRS has challenged the reserve deduction. Other sections of this article also cover IRS rulings on the treatment and valuation of an insurance company stock purchased as an asset acquisition and COLI life insurance.

Description: A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts.

Description: High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in reserving methodology or assumptions will be subject to the “10-year-spread” requirements of section 807f of the Internal Revenue Code. This article discusses possible answers.

Description: A look at the IRS initiative, the Industry Issue Resolution IIR Program, and its requested use to address the tax treatment of hedges of VA contract guarantees. The IIR Program is designed to address tax issues that are common to many business taxpayers and are frequently disputed.

Description: This session discussion is about current developments in the legislative situation and proposed changes, continuing unresolved audit issues, emerging issues of 1984 and later audits, policyholder taxation issues and alternate minimum tax AMT. From Record of the Society of Actuaries Vol. 15, No. 2.

Description: This session from the 1984 SOA Atlanta Meeting covers pending tax legislation with respect to life insurance companies, policyholder taxation and the current legislative outlook.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

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.

Description: Discusses how the December 2017 US tax reform affects smaller insurance companies.

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.