Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: The Internal Revenue Service “the Service” or “IRS” recently released Technical Advice Memorandum 200939019 “the TAM”. The TAM initially caused a stir among some in the insurance tax industry because it disallows a tax deduction that was permitted on the NAIC Annual Statement hereinafter “NAIC statement”. Specifically, the TAM states that unpaid loss adjustment expenses “LAE” for retiree medical benefits may only be deducted in the tax year in which the benefits are included in income by the employee who earned the benefits, despite the fact the amounts were properly included on the NAIC statement and regardless of deductibility of the unpaid LAE under the Internal Revenue Code “the Code”. This article discusses the memorandum.

Description: February 2010 Supplement to the Taxation Section newsletter, Taxing Times. Extensive discussion of the issues in computing statutory and tax reserves for annuities under VA CARVM.

Description: The May 2010 issue of the the Taxation Section newsletter, Taxing Times.

Description: SSAP 10R supersedes Statement of Statutory Accounting Principles No. 10, Income Taxes “SSAP 10” and the new provisions set forth in this accounting principle are effective for year-end 2009 statutory financial statements. If elected, they provide, where appropriate, the ability to admit additional DTAs by increasing the projected realization period from one to three years along with increasing the statutory surplus limitation from 10 percent to 15 percent, provided the entity exceeds certain risk based capital “RBC” thresholds. SSAP 10R also makes explicit and gives definition to the implicit valuation allowance of SSAP 10, and increases transparency through its expanded disclosure requirements for all entities regardless of whether electing the expanded recognition provisions.

Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

Description: A discussion of the tax-related initiatives listed on the IRS Priority Business Plan for 2010 targeting product tax issues and how they relate to the work of the Taxation Section.

Description: A discussion of the many developments affecting taxation of life insurance companies and products.

Description: This article details proposed regulations issued by the IRS that clarify that a single series may be treated as an entity separate from a series organization for federal income tax purposes, even if it is not recognized as a separate entity under local law.

Description: Outgoing editor talks about the history of the newsletter, Taxing Times, and thanks all those who were involved in its inception years ago and those who work on the publication today.