Description: Discusses proposed regulations regarding reserve deductions for certain captives under IRC Section 1502 related to consolidated group intercompany insurance transactions.

Description: This article summarizes the government guidance for protected cells in the insurance context and the ABA Recommendation, and comments on the Notice and ABA Recommendation in light of traditional notions of equity ownership for federal corporate income tax purposes.

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.

Description: The article discusses ACLI's comment letters submitted to Treasury and the IRS in response to the proposed regulations on the Corporate Alternative Minimum Tax and Ranking Member Ron Wyden (D-OR)'s discussion draft of the Protecting Proper Life Insurance From Abuse Act, that would impact the taxation of some to private placement life insurance.

Description: This is an article about how to place value on an annuity benefit.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are required in different states.

Description: Discusses the section 6694 tax return preparer penalty regime and examines how it might potentially apply to other professionals, such as actuaries, who assist those traditionally considered to be tax professionals.

Description: Kory J. Olsen, Taxation Section chair, interviewed Walter Welsh, focusing on the ACLI, retirement issues, and insurance regulation.

Description: Discusses five subjects, including proposed IASB discussion paper, split-dollar life insurance, penalties for paid tax preparers, statutory reserves for insurers, and NAIC securitization initiatives.