Description: The Taxation Section recently conducted a survey to gather information on the role of the tax actuary within insurance companies.

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: The article deals with the critique of a technical advice memorandum issued by the IRS. It basically states the author's opinion that, although the conclusion was correct, the reasoning given was inappropriate.

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: The article reviews the results of a survey conducted by the taxation section to review the responses from its members.

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

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

Description: This dialogue discusses the history and purpose of section 811(a) and its historic role in the computation of life insurance company taxable income and, in particular, reserves.

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: 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.