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 discussion of the effective dates and statutory reserves cap for variable annuities under Actuarial Guideline 43.

Description: Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are required in different states.

Description: Discusses five subjects, including proposed IASB discussion paper, split-dollar life insurance, penalties for paid tax preparers, statutory reserves for insurers, and NAIC securitization initiatives.

Description: A discussion of: IRS requirement disclosures of uncertain tax positions, disallowed interest reductions on earnings and profits, and tax standards for partial worthlessness deductions.

Description: A discussion of, first, the three-year transition period for adopting principle-based reserves and how it might not apply to tax reserves, and second, the tax impact of adding investment options to in-force contracts.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

Description: A discussion about premium deficiency reserves and tax regulations for employer-owned insurance contracts