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: An update from the ACLI staff to keep readers informed about the organization's work on tax issues affecting the life insurance industry.

Description: Article discusses recent changes in the IRS LB&I Division's examination practices and approach that may affect the work-flow of company actuaries and may present opportunities to resolve tax issues for companies

Description: Tax code tidbits

Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

Description: A summary of a recent U.S. District Court decision regarding the applicability of the Federal Excise Tax (FET) on foreign-to-foreign retrocessions.

Description: A discussion of the ramifications, facts and rules associated with loss reserves and underwriting reserves that are held by foreign subsidiaries for life insurance and annuity contracts.

Description: In TAM 201149021, the Internal Revenue Service (the “Service”) National Office has ruled that an insurance contract that insures against a decline in market value of assets leased to third parties is not an insurance contract for federal income tax purposes.

Description: This article is a companion to “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change,” an article written by John T. Adney and Craig R. Springfield (May 2012 Taxing Times Supplement) that describes the various material change rules found in the Code, highlighting the complexities insurers face in navigating through these rules when a life insurance contract is materially changed. The Adney and Springfield article also addresses the difficulties in interpreting the tax law requirements under the various effective date rules contained in the Code sections affecting life insurance contracts.

Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.