Description: One major feature of the OECD's two-pillar regime is that MNEs would base the calculation of taxes due on book-based financial statements. The article provides a summary of how these rules operate along with suggested actions insurers can take today to prepare for timely compliance.

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 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: Taxing Times -- Volume 11, Issue 2, June 2015

Description: This article provides a basic introduction to the taxation of qualified annuities held in qualified retirement plans and IRAs. The article has been updated for the SECURE Act and the SECURE 2.0 Act. The article describes the basic types of employer-based plans, provides of overview of the taxation of contributions and benefits when annuities are held in connection with plans and IRAs, explains the required minimum distribution rules, and offers a brief introduction to recent legislation impacting qualified annuities.

Description: This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk can be identified and assessed.

Description: May 2015 marked the inaugural issue of Taxing Times, the newsletter of the newly-formed Taxation Section of the Society of Actuaries. In the spring of 2015, we recognize this milestone with a trip down memory lane.

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: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.

Description: This article is a general discussion about prior correction procedures for failed life insurance contracts and the new IRS procedure for remediation.