Description: This article focuses on the TCJA’s changes to the provisions for net operating losses (“NOLs”) and highlights some of the challenges surrounding the NOL provisions that insurance companies may face when making business decisions around reinsurance agreements.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

Description: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.

Description: Frequently Asked Questions on tax reserve methods and assumptions, based on law in effect prior to 12/31/2017.

Description: Taxation Section Supplement for the October 2014 newsletter.

Description: The article discusses the practical impact of recently Rev. Rul. 2014-7, which modified and supercedes Rev. Rul. 2007-54 by republishing the position of what variable annuity contract reserves are taken into for tax purposes without addressing the issue of how to calculate required interest for separate accounts; Rev. Rul. 2014-7 also obsoleted Rev. Rul. 2007-61, which had suspended Rev. Rul. 2007-54.

Description: In this article, the authors attempt to provide some guidance on working in the current environment.

Description: The guidance provided by the proposed regulations specifically related to insurance is the first detailed set of rules provided under FATCA and incorporates many of the topics identified as issue areas in the comment letters received by Treasury from domestic and foreign insurance companies and trade associations over the past two years. This article focuses on the provisions that apply specifically to insurance companies.

Description: Update on tax legislation and legislation-related materials relating to life insurers.

Description: Taxing Times, September 2006, Volume 2, Issue No. 2.