Description: An update from the ACLI staff to keep readers informed about the organization's work on tax issues affecting the life insurance industry.

Description: Decade and year in review.

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: ACLI's comments to Treasury and IRS on industry-related guidance.

Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

Description: A discussion of the ramifications, facts and rules associated with loss reserves and underwriting reserves that are held by foreign subsidiaries for life insurance and annuity contracts.

Description: The article discusses the recent final and proposed regulations published by the IRS and Treasury on the required minimum distribution rules for qualified plans, which implement changes made by SECURE 1.0 and SECURE 2.0. The article is intended to identify the important rules in the final regulations, provide a framework for determining how the rules apply to beneficiaries of qualified plans and IRAs, describe the key differences between the earlier 2022 proposed regulations and the final regulations, and it summarizes the SECURE 2.0 provisions contained in the new proposed regulations.

Description: A brief discussion of the articles included in the February 2013 issue of Taxing Times.

Description: A continuation of the conversation about principle-based reserves (PBR). Actuaries and an attorney discuss revisit federal-income tax-related issues as they relate to PBR.