Description: Update from ACLI on tax issues of interest

Description: This article outlines how Bermuda advanced in global tax compliance through the enactment of the Bermuda Corporate Income Tax (CIT) Act of 2023, which will take effect for tax years beginning on or after January 1, 2025. The Bermuda CIT rules incorporate key foundational definitions from the Organization for Economic Cooperation and Development’s (OECD) Pillar Two GloBE model rules, while also exhibiting significant differences from Pillar Two. The article discusses the various elections available for taxpayers, key mechanics of the CIT, and the latest administrative guidance released by the Government of Bermuda.

Description: Legislation imposing new restrictions on a wide range of compensation arrangements was signed into law on October 22, 2004. The American Jobs Creation ActAJCA adds a new section 409A to the Internal Revenue Code, which imposes restrictions on funding, distributions, and elections to participate in nonqualified deferred compensation plans.

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: This article begins with a brief review of the treatment of QAB charges under the Code and the guidance the Internal Revenue Service the “Service” has issued regarding the manner in which taxpayers should account for QAB charges Part I. It then describes Rev. Rul. 2005-6’s three alternatives for addressing improper accounting for QAB charges Part II. It also includes a discussion about an Alternative C closing agreement.

Description: This article describes Health Savings Accounts HSAs and the tax and other aspects of these funds.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

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.