Description: Read the October 2019 issue of Taxing Times, published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: The Chairperson of the Taxation Section discusses how the section will deal with changes to the US Tax Code.

Description: The Taxing Times Editorial Board acknowledges the invaluable contributions of our colleague, Art Schneider, who passed away in August. Throughout his career as a tax accountant, Art generously shared his time and talents to help actuaries and other tax professionals increase their understanding of insurance industry tax topics. We will miss him.

Description: This article outlines how Bermuda advanced in global tax compliance through the enactment of the Bermuda Corporate Income Tax (CIT) Act of 2023, which will take effect for tax years beginning on or after January 1, 2025. The Bermuda CIT rules incorporate key foundational definitions from the Organization for Economic Cooperation and Development’s (OECD) Pillar Two GloBE model rules, while also exhibiting significant differences from Pillar Two. The article discusses the various elections available for taxpayers, key mechanics of the CIT, and the latest administrative guidance released by the Government of Bermuda.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: The article discusses a recent IRS private letter ruling granting IRC section 72(b) exclusion ratio treatment for amounts received from an innovative payout option.under a deferred variable annuity.

Description: This article outlines the IRS directive published in July 2014, which provides a safe harbor treatment for variable annuity hedging gains and losses relating to VA contracts issued before Dec. 31, 2009.

Description: This article briefly summarizes the history of the Passive Foreign Investment Company (PFIC) tax regime. Then it provides a detailed description of the PFIC proposed regulations issued in July of 2019.

Description: Notice 2004-611 is the latest in a series of administrative pronouncements from the Internal Revenue Service related to the appropriate mortality assumptions to be used in computing the definitional limitations under Internal Revenue Code Section 7702 and the seven-pay limitation under the Section 7702A modified endowment rules.