Description: An extensive look at Actuarial Guideline 38, "The Application of the Valuation of Life Insurance Policies Model Regulation."

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

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: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: Highlights of recent American Council of Life Insurers (ACLI) activities

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

Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Kory J. Olsen, Taxation Section chair, interviewed Walter Welsh, focusing on the ACLI, retirement issues, and insurance regulation.

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.