Description: The Internal Revenue Service “the Service” or “IRS” recently released Technical Advice Memorandum 200939019 “the TAM”. The TAM initially caused a stir among some in the insurance tax industry because it disallows a tax deduction that was permitted on the NAIC Annual Statement hereinafter “NAIC statement”. Specifically, the TAM states that unpaid loss adjustment expenses “LAE” for retiree medical benefits may only be deducted in the tax year in which the benefits are included in income by the employee who earned the benefits, despite the fact the amounts were properly included on the NAIC statement and regardless of deductibility of the unpaid LAE under the Internal Revenue Code “the Code”. This article discusses the memorandum.

Description: The Chairperson of the Taxation Section shares the section council's plans and goals for 2017

Description: Synopsis of Issue Brief prepared by Tax Work Group of the Academy-LTD Claim Reserve Assumption Basis: Use of date of incurral/date of issue of original policy.

Description: The Taxing Times editor discusses what is in the current issue as well as Obama adminstration tax proposals affecting the insurance industry such as notification requirements and COLI. Also mentioned are IRS expected guidance on deficiency reservs and 7702 defining cash surrender value.

Description: Taxing Times -- Volume 11, Issue 2, June 2015

Description: A discussion of the plans for the Taxation Section including educational offerings, seminars and the section newsletter.

Description: This article discusses tax and accounting issues that arise under a recently-issued Chief Counsel Advice in which the IRS applied a life insurance company tax rule to a nonlife company that issues life insurance products

Description: This article summarizes a recent revenue ruling concerning the insurance company qualification of an affiliate that reinsures retiree health benefits under an arrangement entered into by a VEBA.

Description: The recent Tax Technical Corrections Act of 2007, Pub. L. 110-172, signed into law on Dec. 29, 2007, includes a provision that permits a taxpayer to select positions in a straddle and thereby avoid surprise applications of the straddle rules by the IRS on audit.

Description: Two relatively recent developments have heightened tax managers’ anxiety concerning the possible disclosure of tax accrual workpapers.