Description: February 2010 Supplement to the Taxation Section newsletter, Taxing Times. Extensive discussion of the issues in computing statutory and tax reserves for annuities under VA CARVM.

Description: SSAP 10R supersedes Statement of Statutory Accounting Principles No. 10, Income Taxes “SSAP 10” and the new provisions set forth in this accounting principle are effective for year-end 2009 statutory financial statements. If elected, they provide, where appropriate, the ability to admit additional DTAs by increasing the projected realization period from one to three years along with increasing the statutory surplus limitation from 10 percent to 15 percent, provided the entity exceeds certain risk based capital “RBC” thresholds. SSAP 10R also makes explicit and gives definition to the implicit valuation allowance of SSAP 10, and increases transparency through its expanded disclosure requirements for all entities regardless of whether electing the expanded recognition provisions.

Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

Description: A discussion of the tax-related initiatives listed on the IRS Priority Business Plan for 2010 targeting product tax issues and how they relate to the work of the Taxation Section.

Description: A discussion of the many developments affecting taxation of life insurance companies and products.

Description: This article details proposed regulations issued by the IRS that clarify that a single series may be treated as an entity separate from a series organization for federal income tax purposes, even if it is not recognized as a separate entity under local law.

Description: Discusses the IASB insurance contract project and the major components of the new accounting standard, including the guidance it provides regarding how to define the term “insurance contract.”

Description: Discusses of the application of disproportionate asset acquisition rules under the life/nonlife regulations. How the amount of premiums or reserves should be measured is also discussed in detail.

Description: A discussion of the bill that will require tax reporting of sales of interests in life insurance policies. This bill will require the buyer of an interest in a life insurance policy to report the sale to the Internal Revenue Service and notify the life insurer that issued the policy.

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.