Description: The PPACA imposed a market share-based health insurance provider fee, known as the "Section 9010 Fee", "Health Insurer Fee", or simply the "HIF", on each “covered entity” with net premiums written in excess of $25 million that is engaged in the business of providing health insurance coverage for U.S. health risks. This article provides background information to help unpack the language behind the Section 9010 Fee and highlights a few areas of special interest including merger and acquisition-related issues, application of the Section 9010 fee to expatriate plans, and considerations regarding fee administration.

Description: Recurring column from the Chair of the Taxation Section of the Society of Actuaries.

Description: The article summarizes PLRs 201515001 and 201519001, in which the IRS addressed the treatment of a non-qualified deferred annuity contract under the investor control doctrine and other applicable rules. The contract provides a guaranteed lifetime withdrawal benefit and investment options that correspond to “public” mutual funds. The IRS concluded that the investor control doctrine will apply to treat the contract purchaser as the owner of the mutual fund shares for federal income tax purposes. The IRS also addressed certain other tax aspects of the arrangement. The effect of the rulings is that the contract will be taxed similarly to a contingent deferred annuity (where the policyholder holds the mutual fund shares in his or her own brokerage account), while being structured like a traditional deferred variable annuity (where the insurance company holds the shares in its separate account).

Description: This is a letter to the editor regarding the October 2014 Taxing Times supplement on the Camp proposals on the taxation of life insurance companies.

Description: Provides information on Section 7702 mortality requirements, the implications of the adoption of the 2017 CSO tables and the need for IRS guidance.

Description: Update on industry action on legislative and tax regulatory items affecting the life insurance industry.

Description: This article discusses IRS Notice 2016-32.

Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: Read the October 2017 issue of Taxing Times published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Overview of reinsurance: its purpose and uses, its different forms, and the tax results and issues that can arise in reinsurance transactions.