Description: In order to encourage health insurance issuers to offer health insurance coverage on the Exchange and on the individual and small group markets, while ameliorating the potential impact on any particular health insurance issuer of providing coverage without pricing for pre-existing conditions or the gender of the insured, the Affordable Care Act includes three risk-sharing programs: the Transitional Reinsurance program, the Risk Corridor program and the Risk Adjustment program (collectively referred to as the “3Rs”). The financial and tax reporting of each health insurance issuer is affected by the implementation of these risk-sharing programs because each health insurance issuer is required to pay for the programs’ costs, and some issuers are or will be eligible for benefits under them.

Description: Last March, Congress passed and the President signed the Patient Protection and Affordable Care Act followed by the Health Care and Education Reconciliation Act, which amended the former collectively, the “Act”. The article provides a brief background on the passage of the Act generally and the creation of the new Investment Income Tax in particular compares the existing provisions of the HI tax with the newly enacted provisions, and it then analyzes the import of the Investment Income Tax for annuities and, possibly, life insurance contracts. The article concludes with thoughts on the potential effect of the new tax on the annuity marketplace.

Description: Discusses Notice 2011-02 as it addresses most, but not all, of the outstanding questions about health-care-insurance entities to which the $500,000 compensation rule applies.

Description: Provides a summary of recent proposed regulations for the health insurer fee, section 9010 of the Affordable Care Act (ACA).

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: The author discusses some common myths about Congress’ tax policy under the 1984 Act that he would like “to debunk.”

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

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: Notice 2004-611 is the latest in a series of administrative pronouncements from the Internal Revenue Service related to the appropriate mortality assumptions to be used in computing the definitional limitations under Internal Revenue Code Section 7702 and the seven-pay limitation under the Section 7702A modified endowment rules.

Description: Tells what occurred after the adverse private letter ruling PLR 200738016 up to the issuance of the revenue procedure, and offers some speculation about the future.