Description: A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts.

Description: The author discusses some common myths about Congress’ tax policy under the 1984 Act that he would like “to debunk.”

Description: High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in reserving methodology or assumptions will be subject to the “10-year-spread” requirements of section 807f of the Internal Revenue Code. This article discusses possible answers.

Description: Discussion about the recent activities of the Taxation Section and its council and plans for the future. The project of the NPT [Necessary Premium Test] task force was discussed.

Description: On June 26, 2013, the Supreme Court released its decision in the case of United States v. Windsor, Executor of the Estate of Spyer, et al. addressing the constitutionality of the federal Defense of Marriage Act (“DOMA”). This article explores the implications for life insurance and annuity contract spousal provisions that are governed by federal law.

Description: On April 24, 2015, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-108214-15) that provide guidance regarding when a foreign insurance company’s income is excluded from the definition of passive income under Section 1297(b)(2)(B). The proposed regulations are directed at hedge funds that purport to establish a foreign reinsurance company in an effort to avoid treatment as a passive foreign investment company (PFIC), but could have unintended consequences for traditional insurance companies.

Description: The Tidbit summarizes LTRs 201609008 and 201613016 and discusses the definition of insurance under the tax code in light of these new pieces of guidance from the IRS.

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

Description: The Required Minimum Distribution [RMD] working group of the Taxation Section has completed research in determing the actuarial present value of additional benefits for computing RMD under deferred annuity contracts. This Appendix E spreadsheet is for the Guaranteed Minimum Withdrawal Benefit [GMWB] calculation. See the SOA website research section for the complete report and excel spreadsheet for the other appendices.

Description: SECURE 2.0 included provisions that improve the ability of insurers to serve those who own qualified annuities. Several previously disallowed distribution methods are now allowed. These changes should increase the availability and desirability by contract owners to choose a payout annuity compared to required minimum distributions. An insurer considering enhancing qualified annuitization offerings might follow the approach outlined to potentially increase qualified annuitization sales and assist contract owners in protecting their principal more directly than previously.