Description: In Schaeffler v. United States, the United States Court of Appeals for the Second Circuit issued a taxpayer-friendly decision on the scope of the attorney-client privilege and the work-product doctrine. The article explores the case and its meaning for the two doctrines, and specifically how it differs from the decision in United States v. Textron in the First Circuit.

Description: The article discusses an IRS private letter ruling applying the after-death distribution requirements applicable to non-qualified annuity contracts under section 72(s) of the Internal Revenue Code.

Description: This article discusses IRS Notice 2016-32.

Description: Internal Revenue Code (I.R.C.) §§243–2461 provide that a corporation is allowed a percentage deduction for dividends received from other corporations (the DRD). In addition to the general corporate rules regarding the DRD, if the recipient of a corporate dividend is a life insurance company, I.R.C. §812(a) further allocates the benefit of the DRD between the company’s share and the policyholders’ share. This allocation methodology is often referred to as proration. Proration has historically involved a complex and at times contentious2 formulaic process.

Description: The Wells Fargo case highlights the importance of creating and preserving documentation establishing actuarial and legal foundations for return positions.

Description: Discusses the peer-review process as it relates to articles submitted for TAXING TIMES.

Description: This article provides a high-level description of how the One Big Beautiful Bill passed enacted on July 4, 2025 specifically affects life insurers. Primarily in this article, ACLI reflects on its 18-year collaboration with the Society of Actuaries through the Taxing Times publication, highlighting key tax legislation impacts and ongoing advocacy for the life insurance industry. This final column acknowledges past achievements and emphasizes continued commitment to industry representation amid evolving challenges.

Description: Discussion of recent developments in the taxation of noncoordinated benefits such as fixed indemnity, hospital indemnity, and specified disease insurance policies. Developments include a recent Chief Counsel Advice Memorandum and proposed triagency rulemaking that would impact non coordinated benefits.

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