Description: Discussion of the March 1, 2013 Internal Revenue Service (“IRS”) release of PLR 201309011, which addresses the application of the section 817(h) diversification requirements to variable contracts that have invested in illiquid investment vehicles (the “Funds”).

Description: Update on accounting and capital/RBC issues subsequent to tax reform.

Description: When a life insurance company changes its basis for computing tax reserves, a special 10-year spread rule found in section 807(f) of the Internal Revenue Code applies to the change. But, what happens if the statutory accounting for original issue discount (OID) or bond premium changes? A discussion follows.

Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

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: Update on tax reform

Description: The article describes the IRS Industry Issue Resolution (IIR) process as applied to the Insurance Industry's Bad Debt Issue. The article describes the IRR process in general, how that process was applied to the bad debt issue, and the safe harbor approach available for insurance companies. The safe harbor is described in LB&I Commissioner Heather Maloy's Directive dated July 30, 2012 (LB&I-4-0712-009).

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: This article describes how there are many kinds of plans and arrangements under which qualified annuities are issued, and the rules governing them differ considerably.

Description: Discusses taxation of derivatives, as changed for some types under Dodd-Frank and not changed for others.