Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: The article describes changes to the computation of tax reserves as a result of the Tax Cuts and Jobs Act.

Description: T3: TAXING TIMES TIDBITS

Description: On June 17, 2019, the Internal Revenue Service published Final Regulations implementing changes to loss reserve discounting under section 846 of the Internal Revenue Code made by the Tax Cuts and Jobs Act. This note addresses changes made in the Final Regulations, particularly modification of rules for determining the interest rate used for discounting, in response to comments from taxpayers on the proposed regulations.

Description: This article discusses tax and accounting issues that arise under a recently-issued Chief Counsel Advice in which the IRS applied a life insurance company tax rule to a nonlife company that issues life insurance products

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

Description: This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing tax reserves for pre-2018 tax years for annuity contracts subject to AG43 and VM-21 and life insurance contracts subject to VM-20 Principal Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain spread amounts in some cases to future tax years starting in 2018.

Description: The article discusses recently-issued regulations under section 807 of the Internal Revenue Code, concerning the computation and reporting of reserves. The provisions addressed generally relate to the Tax Cuts and Jobs Act of 2017.

Description: Changes to AG 43 and what that might mean for tax purposes. Also, summary of IRS Notice 2016-63 (provides safe harbor tax guidance on use of 2017 CSO tables).

Description: Discusses the CCA 201939003 and the conclusions that were made and the impacts it has on a taxpayer's ability to make an election for determining the interest rate used to compute tax-deductible life insurance reserves.