Description: This article summarizes the government guidance for protected cells in the insurance context and the ABA Recommendation, and comments on the Notice and ABA Recommendation in light of traditional notions of equity ownership for federal corporate income tax purposes.

Description: This letter discusses answers to the question “Is Homogeneity Required to Qualify as Insurance?”

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.

Description: This article is a discussion of the proposal to tax the inside build-up in life insurance policies and the consequences if it were to be adopted.

Description: Discusses the peer-review process as it relates to articles submitted for TAXING TIMES.

Description: The Taxation Section of the Society of Actuaries recently conducted a survey of its members to get a better understanding of how actuaries are being utilized in areas where tax plays a role within the insurance industry. The results of the survey are discussed in this article.

Description: On March 25, 2010, the Treasury and IRS issued Notice 2010-29. The new Notice follows-up Notice 2008-18, in which the Treasury Department Treasury and the Internal Revenue Service IRS identified concerns regarding proposed Actuarial Guideline VACARVM and suggested approaches that might be taken to address those issues. Actuarial Guideline VACARVM was effective, as AG43, beginning on Dec. 31, 2009. This discussion is the fourth in a continuing series of interdisciplinary dialogues in TAXING TIMES on selected tax issues related to proposals regarding principle-based reserves.

Description: Chamberlin's first column as section chair, thanking outgoing chairman Christian DesRochers for his excellent leadership, and also thanking others and encouraging participation.

Description: Updates on partial annuitization and exhanges, prevailing CSO valuation mortality tables, disclosure of offshore accounts through FATCA.

Description: Discusses the problem with the computation of tax reserves for VA contracts with Guaranteed Living Benefit riders that were issued prior to December 31, 2009.