Description: Our third issue of Taxing Times arrives just as 2005 is coming to an end. Reflecting back on this past year, I am amazed and pleased with how much the Taxation Section has accomplished.

Description: This article discusses the Section 338h10 election on the disposition of an insurance company.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.

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: A discussion of the Treasury’s Priority Guidance Plan for the year July 2010 through June 2011.

Description: A discussion of substantially equal periodic payments, SEPPs, and the penalty tax that is associated with SEPPs, the Recapture Rule. Computation methods are also discussed.

Description: A description about current efforts of several Central and Southern Europen countries to improve penetration and density of insurance coverage, in the personal view of Renata De Leers. De Leers has spent many years consulting with regulators and industry leaders, and is an advocate of inclusive insurance solutions, as a way to foster economic development.

Description: The article discusses the role played by the "Blue Books" issued by the Congress's Joint Committee on Taxation and the authority accorded them by a recent U.S. Supreme Court decision.

Description: The article reviews the creation and interpretation of federal tax law, with specific application to the life insurance industry