Description: This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing tax reserves for pre-2018 tax years for annuity contracts subject to AG43 and VM-21 and life insurance contracts subject to VM-20 Principal Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain spread amounts in some cases to future tax years starting in 2018.

Description: Discusses the achievements of the Taxation Section in 2009 – tax education opportunities, expanded section involvement at meetings expansion of tax content on the SOA exams.

Description: A discussion of how issuers and providers of IRAs and employer-provided qualified retirement plans need to consider all situations and possibly modify their administrative systems and/or procedures for purposes of administering the IRAs and plans in accordance with the RMD required minimum distribution rules.

Description: Last March, Congress passed and the President signed the Patient Protection and Affordable Care Act followed by the Health Care and Education Reconciliation Act, which amended the former collectively, the “Act”. The article provides a brief background on the passage of the Act generally and the creation of the new Investment Income Tax in particular compares the existing provisions of the HI tax with the newly enacted provisions, and it then analyzes the import of the Investment Income Tax for annuities and, possibly, life insurance contracts. The article concludes with thoughts on the potential effect of the new tax on the annuity marketplace.

Description: Discusses PLR 201046008, regarding addition of a rider to a variable life policy that provides a minimum annual amount of withdrawal or policy loan. Includes discussion of impact on NSP under CVAT, and Guideline Premium.

Description: The article provides an introduction to tax accounting for U.S. life insurance companies, with a focus on NAIC statutory accounting concepts. The author discusses permanent and temporary differences, the current tax provision, and deferred tax accounting requirements, including admissibility testing under SSAP No. 101.

Description: Chairperson's column for the October 2020 issue of Taxing Times with thoughts on the effects of COVID-19 on the Taxation Section.

Description: The article discussing the differing tax definitions of life insurance in the US and Canada and relates them to new international tax reporting regimes such as FATCA.

Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without any published guidance on when annuity payments can be used to satisfy the SEPP [Substantially Equal Periodic Payments] exceptions to the 10 percent penalty tax under sections 72q2D and 72t2Aiv. This article discusses that problem. The insurance industry requested guidance on this issue.8