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: The Impact of Tax Reform on Federal LTCI Deductibility for Business Owners.

Description: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: Discusses reasons for recent extensive industry changes in premium rates and expected trends, merits of different types of federal income tax treatment in financial statements, and discussion of merits of proposed state regulations regarding classification and allocation of income and expenses.

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: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: The purpose of this paper is to set forth a mathematical technique which in the author's experience has proved useful in testing the tax implications of various management actions.