Description: The article provides guidlines for the proper way to correct several types of tax reserve errors.

Description: The article suggests that the case of State Farm Mutual Automobile Ins. Co. v. Commissioner, 698 F.3d 357 (7th Cir. 2012), and INT 03-17 may support the argument that estimated extra-contractual obligations are deductible by life insurance companies

Description: The column summarizes tax and retirement matters that ACLI and its member companies have been actively addressing. These include IRS 2015-2016 priority guidance items, the Department of Labor proposed fiduciary rule, proposed IRS hedge fund reinsurance rules, and new IRS notional principal contract rules.

Description: Recently, the IRS eliminated one of the more amorphous tax rules that at times was a stumbling block in Triple-X securitization transactions. Unfortunately, however, the IRS left an equally amorphous consolidated return rule untouched.

Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.