Description: Synopsis of Issue Brief prepared by Tax Work Group of the Academy-LTD Claim Reserve Assumption Basis: Use of date of incurral/date of issue of original policy.

Description: The Taxing Times editor discusses what is in the current issue as well as Obama adminstration tax proposals affecting the insurance industry such as notification requirements and COLI. Also mentioned are IRS expected guidance on deficiency reservs and 7702 defining cash surrender value.

Description: The article provides a brief description of the major financial reporting systems applicable to insurance companies. It also discusses the interplay between book and tax accounting as well as a few of the more common differences among the accounting systems.

Description: Taxing Times -- Volume 11, Issue 2, June 2015

Description: Read the October 2016 edition of Taxing Times.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.

Description: Review of section and council activities over past year.

Description: A discussion of the plans for the Taxation Section including educational offerings, seminars and the section newsletter.

Description: This article considers PLR 201304003, which addressed the application of Internal Revenue Code section 1035 to the exchange of a survivorship, or “second-to-die,” life insurance contract after the death of one of the insureds for a new life insurance contract covering only the life of the surviving insured.