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T3: TAXING TIMES TIDBITS
In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counterparty obligated to a domestic corporation (“Taxpayer”) under ...- Authors: Frederic Gelfond
- Date: Aug 2021
- Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Reinsurance; Reinsurance>General reinsurance
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Assessing the Transfer of Risk: An Actuarial Perspective
Assessing the Transfer of Risk: An Actuarial Perspective This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an ...- Authors: Christian J DesRochers
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments>Risk measurement - Finance & Investments; Finance & Investments>Value at risk - Finance & Investments; Reinsurance
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The Mystery of PLR 201006002
The Mystery of PLR 201006002 An explanation of the reasons why the IRS should rule on the application of section 351 to the transfer of assets and reserves in an indemnity coinsurance transaction ...- Authors: Julie V Goosman, Lori J Jones
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance
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T3: Taxing Times Tidbits
T3: Taxing Times Tidbits Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.- Authors: Mark E Griffin, Craig R Springfield, Daniela Stoia, Biruta P Kelly
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy; Reinsurance
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Removal of Profit/Loss Separation Rule from Life/Nonlife Regulations Eliminates Tax Issue from SecuritizingTriple-X Business
Removal of Profit/Loss Separation Rule from Life/Nonlife Regulations Eliminates Tax Issue from SecuritizingTriple-X Business Recently, the IRS eliminated one of the more amorphous tax rules that ...- Authors: Michael A Bell
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations
- Publication Name: Taxing Times
- Topics: Life Insurance>Reserves - Life Insurance; Public Policy; Reinsurance>Life reinsurance
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In the Beginning… A Column Devoted to Tax Basics The Taxation of Reinsurance Transactions
In the Beginning… A Column Devoted to Tax Basics The Taxation of Reinsurance Transactions Overview of reinsurance: its purpose and uses, its different forms, and the tax results and issues that ...- Authors: ELI KATZ, Jean Baxley
- Date: Oct 2017
- Competency: Results-Oriented Solutions>Actionable recommendations; Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
- Topics: Reinsurance>General reinsurance
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The Impact of BEAT on U.S.-Foreign Affiliated Reinsurance
The Impact of BEAT on U.S.-Foreign Affiliated Reinsurance 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 ...- Date: Dec 2020
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Reinsurance
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Unique Tax issues in LTC transactions
Unique Tax issues in LTC transactions Tax considerations in structuring and pricing long-term care transactions. Includes consideration around the form of reinsurance and the unified loss rules ...- Authors: Peter J Sproul
- Date: Mar 2019
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Long-term Care; Reinsurance
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Insurance Transfer Pricing: Issues For Life Reinsurance Transactions
Insurance Transfer Pricing: Issues For Life Reinsurance Transactions This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a ...- Authors: Christian J DesRochers
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance