Description: February 2009 issue of the Taxation Section newsletter, Taxing Times

Description: This article provides the reader with some insights regarding tax planning under the new required methodology.

Description: This article discusses risk transfer and how difficult it is to define and describe. For actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk can be identified and assessed.

Description: This article discusses how new and current industry tax topcs can educate the Taxation Section membership.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: A discussion of the effective dates and statutory reserves cap for variable annuities under Actuarial Guideline 43.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: This article discusses recent proposals made by the American Council of Life Insurers related to: life insurance reserves annuity reserves and risk-based capital risk-based capital for investments and accounting for Deferred Tax Assets.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.