Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.

Description: Overview of latest developments on IRC Section 7702, IRC Section 848, market value adjusted contracts, companies in rehabilitation and Canadian issues including: • Part I income tax • Part IV capital tax

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

Description: From the 1960 Transactions Vol. 12 No. 32, this ‘Discussion of Subjects of Special Interest’ addresses the Life Insurance Company Income Tax Act of 1959.

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: Presented at May 1996 Spring Meeting. This session addresses potential changes in life insurance and annuity markets under alternative tax systems, that is, value-added tax 'VAT' or consumption taxes, and flat taxes and the impact of those changes.

Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

Description: Presented at June 1985 Spring Meeting. Discusses tax changes, company impact including reserve issues, product impact, and reinsurance.

Description: As part of tax reform introduced effective at the beginning of 1988, a major revision of the taxation of life insurance companies operating in Canada occurred. This guide highlights specific legislation, discussion papers, policyholder taxation and history of such legislation.