Description: Update on Life Insurer Legislative and Regulatory issues

Description: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.

Description: Dialogue between Peter Winslow, a tax attorney, and Edward Robbins and Christian DesRochers, tax actuaries, on selected tax issues related to proposals to change statutory reserving from a formula-based methodology to a principles-based approach.

Description: Status update on the Separate Account Dividends Received Deduction, SADRD.

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.

Description: Tidbits relate to contingent deferred annuities, wellness benefits in qualified long-term care contracts, and reactivating the active financing exception for insurance companies.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.