Description: The rules governing the tax treatment of distributions from life insurance or annuity contracts are complex. Worse, the relevant IRC section, section 72, seems at times to be the product of a conspiracy in restraint of understanding.

Description: The Chairperson addresses the readers.

Description: This article addresses changes to the IRS Appeals Conference.

Description: Provides a summary of recent proposed regulations for the health insurer fee, section 9010 of the Affordable Care Act (ACA).

Description: The proposed regulations define a class of products known as “qualifying longevity annuity contracts” (QLACs), which are excluded from the account balance used to determine required minimum distributions. By exempting longevity annuities (up to a specified limit) from the RMD rules, it is hoped that it will provide individuals under defined-contribution plans the option to use an “affordable” portion of their account balance to purchase a longevity annuity. The proposed regulations apply to tax-qualified defined-contribution plans under section 401(a), section 403(b), individual retirement annuities and accounts (IRAs) under section 408, and eligible governmental section 457 plans.

Description: Part II of a three part series of articles discussing the extent to which the Internal Revenue Code gives deference to NAIC and state regulatory insurance concepts and rules in insurance classification and accounting concepts for tax purposes.

Description: Company Tax Issues

Description: The Internal Revenue Code Requires Companies to Use Statutory Reserve Assumptions for Tax Reserves (Except Where It Doesn’t)

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

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.