Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

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 article describes changes to the computation of tax reserves as a result of the Tax Cuts and Jobs Act.

Description: This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing tax reserves for pre-2018 tax years for annuity contracts subject to AG43 and VM-21 and life insurance contracts subject to VM-20 Principal Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain spread amounts in some cases to future tax years starting in 2018.

Description: The article provides an introduction to tax accounting for U.S. life insurance companies, with a focus on NAIC statutory accounting concepts. The author discusses permanent and temporary differences, the current tax provision, and deferred tax accounting requirements, including admissibility testing under SSAP No. 101.

Description: This article briefly summarizes the history of the Passive Foreign Investment Company (PFIC) tax regime. Then it provides a detailed description of the PFIC proposed regulations issued in July of 2019.

Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: Chairperson's column for the October 2020 issue of Taxing Times with thoughts on the effects of COVID-19 on the Taxation Section.

Description: TAXING TIMES recently sat down with a group of retired tax actuaries to hear about how they got involved in actuarial tax matters and how their tax experience impacted their careers. Their insights will be useful for actuaries who are just starting out in the profession, as well as more seasoned actuaries.

Description: The article describes recently proposed regulations on the deduction of partially-worthless debts under section 166. It also provides background on the comments submitted by the insurance industry in response to the proposed regulations and additional guidance issued by Treasury and the IRS following the publication of the proposed regulations.