Description: Enacted pursuant to the 2017 Tax Cuts and Jobs Act (TCJA) , the base erosion and anti-abuse tax (BEAT) is one of the most dramatic changes to the U.S. international tax landscape in recent years. The BEAT is essentially a minimum tax which applies to certain large U.S. and foreign corporations with U.S. operations with average annual gross receipts of at least $500 million and a base erosion percentage of 3 percent or higher (with some exceptions).

Description: IRS published final regulations on updated life expectancy and distribution period tables used for determining RMDs. The article intends to provide an overview on the development of the final regulations and highlight the key updates in final regulations, the transition rules to apply final regulations and some of the relevant issues not addressed in final regulations (e.g. MITT, Rev. Rul. 2002-62 and Notice 2004-15). The article also briefly discusses what financial institutions and actuaries would like to do before the regulations become effective on Jan. 1, 2022.

Description: The article discusses the impact of changes made to Internal Revenue Code Section 7702 by the ConsolidatedAppropriations Act, 2021. The Consolidated Appropriations Act made changes to the interest rates used calculatethe Section 7702 premium and cash value funding limitations for life insurance contracts

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: TAXING TIMES recently sat down with a group of retired tax actuaries to hear about how they got involved in actuarial tax matters and how their tax experience impacted their careers. Their insights will be useful for actuaries who are just starting out in the profession, as well as more seasoned actuaries.

Description: This article summarizes IRS guidance on what constitutes a change in basis for computing life insurance reserves under the Internal Revenue Code.

Description: Summary of Administration's FY 2023 Tax Proposals of Interest to Life Insurers

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

Description: T3: TAXING TIMES TIDBITS