Description: A discussion of: IRS requirement disclosures of uncertain tax positions, disallowed interest reductions on earnings and profits, and tax standards for partial worthlessness deductions.

Description: Update to initial article in Sept. 2007 issue, because of two new revenue rulings: Rev. Rul. 2007-54, 2007-38 I.R.B. 604 and Rev. Rul. 2007-61, 2007-42 I.R.B. 799.

Description: After nearly a decade of work by ACLI and representatives of its member companies, the Society of Actuaries SOA, the American Academy of Actuaries Academy, and the NAIC’s Life and Health Actuarial Task Force LHATF, on Sept. 24, 2008, the NAIC adopted a new actuarial guideline for applying the method of computing statutory reserves for variable annuity contracts AG VACARVM.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

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: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

Description: Examines the Treasury Department and IRS guidance in determining whether a financial arrangement qualifies as insurance under federal tax law. It concerns the concepts of fortuity, homogeneity, and risk distribution, among others.

Description: SSAP 101 is the new standard which replaces the current temporary guidance set forth under SSAP No. 10R regarding deferred tax assets [DTAs] and Tax Contingency Reserves.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

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.