Description: Summary of private letter ruling the IRS released in February 2013 regarding a partnership formed to hold and manage bank-owned life insurance contracts. The article follows up another article from the same authors in the May 2012 issue of Taxing Times regarding an earlier ruling on a similar structure.

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: Overview of sessions and highlights from the 2012 Product Tax Seminar held in Washington DC in September 2012.

Description: On April 24, 2015, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-108214-15) that provide guidance regarding when a foreign insurance company’s income is excluded from the definition of passive income under Section 1297(b)(2)(B). The proposed regulations are directed at hedge funds that purport to establish a foreign reinsurance company in an effort to avoid treatment as a passive foreign investment company (PFIC), but could have unintended consequences for traditional insurance companies.

Description: A comprehensive look at Actuarial Guideline 43 VA CARVM. This article examines the statutory and tax implications of AG 43 for the determination of reserves for annuity writers.

Description: A discussion of tail-design LTC riders for annuities and how contract cash values are offset by reductions to the annuity contract. LTC benefits, and how they relate to the annuity contracts, are also discussed.

Description: A discussion about premium deficiency reserves and tax regulations for employer-owned insurance contracts

Description: Update on section activities from the chairperson.

Description: A review of the different entities reading the newsletter, including actuaries, lawyers, accountants, tax professionals and government personnel.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.