Description: This article discusses tax and accounting issues that arise under a recently-issued Chief Counsel Advice in which the IRS applied a life insurance company tax rule to a nonlife company that issues life insurance products

Description: This article summarizes a recent revenue ruling concerning the insurance company qualification of an affiliate that reinsures retiree health benefits under an arrangement entered into by a VEBA.

Description: In February 2015, the Internal Revenue Service Chief Counsel appointed Alexis MacIvor as the chief of Branch 4 of the Office of the Associate Chief Counsel (Financial Institutions & Products). That branch (sometimes referred to by our readers as the “Insurance Branch”) has seven attorneys who work exclusively on issues concerning the taxation of insurance companies and the products those companies issue. Because of the importance of that branch’s work product to the issues that life actuaries must address every day, the Taxing Times Editorial Board and the Taxation Section Council thought our readers would appreciate the opportunity to meet Alexis and welcome her to the insurance tax actuarial community. Mark Smith of our editorial board recently met with Ms. MacIvor to talk about her background and her new role.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

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.