Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

Description: Current tax issues affecting the insurance industry, including the Inflation Reduction Act (Budget Reconciliation Bill)'s tax provisions, including the corporate minimum book income tax and share repurchase (or stock buyback) excise tax; the tax treatment of non coordinated benefits (also known as fixed indemnity benefits); and an update on the OECD’s Base Erosion and Profit Shifting Project

Description: This update column from ACLI addresses the 2020 year-end spending and relief package with specific emphasis on its effect on the life insurance industry

Description: This article briefly summarizes the history of the Passive Foreign Investment Company (PFIC) tax regime. Then it provides a detailed description of the PFIC proposed regulations issued in July of 2019.

Description: This update column from ACLI the “General Explanations of the Administration’s Revenue Proposals for Fiscal Year 2022” (Green Book).

Description: This article discusses the guidance provided in IRS Notice 2022-6 and prior guidance on whether distributions from an individual account under a qualified retirement plan satisfy the exception to the 10 percent additional tax in Internal Revenue Code section 72(t) for certain substantially equal periodic payments.

Description: This article presents a high-level overview of the Federal Income tax rules in section 382 regarding limitations on the use of losses after an ownership change takes place and summarizes problems and issues for the insurance industry in proposed regulations under section 382 as summarized in comments made by the industry and the ACLI

Description: A summary and analysis of REG-103163-18, the proposed regulations providing guidance for property-casualty loss reserve discounting (LRD) under IRC Section 846.

Description: Update on industry federal tax legislative and regulatory issues

Description: Update from the life insurance industry trade's perspective on tax policy and political issues