Description: This article discusses key tax issues that exist under current law with respect to asset rebalancing and hedging transactions that an insurance company might undertake.

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

Description: I.R.C. § 4371 imposes an excise tax on policies issued by foreign insurers or reinsurers covering U.S. risks. The application of the tax to funds withheld reinsurance can raise difficult questions. The IRS’s position is that an accrual concept applies, although that position is questionable. Taxpayers that instead determine the excise tax by looking only to actual payments made by the ceding company to the reinsurer or to the net amount of the ceded premiums after adjusting for the allowance paid by the reinsurer have a variety of arguments to support their position. The language of the premium excise tax, the regulations thereunder, the legislative history of the provision, and the very nature of an excise tax all support the position that the tax applies only when there is an actual payment. Other Code provisions that use similar language as well as the Supreme Court also support this view.

Description: Overview of articles in the October 2013 issue of TAXING TIMES.

Description: The article discusses court decisions on the tax basis and taxable gain in life insurance contracts.

Description: In Schaeffler v. United States, the United States Court of Appeals for the Second Circuit issued a taxpayer-friendly decision on the scope of the attorney-client privilege and the work-product doctrine. The article explores the case and its meaning for the two doctrines, and specifically how it differs from the decision in United States v. Textron in the First Circuit.

Description: Read the February 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: A detailed discussion on Private Letter Ruling 20123009 which states that owners of life insurance contracts in some circumstances want to decrease their death benefits and that the decreases contemplated are not ones resulting from application of a formula or other provision set forth in the contracts.

Description: Read the June 2018 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Primer on the federal income taxation of nonqualified annuities