Description: This article discusses key tax issues that exist under current law with respect to asset rebalancing and hedging transactions that an insurance company might undertake.

Description: Chairperson column - update on section activity

Description: Read the June 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: This article discusses several issues related to the IRS and taxation. These include partial exchanges of non-qualified annuity contracts, Long Term Care features on Annuity or Life contracts, and the applicability of the Foreign Account Tax Compliance Act [FATCA] to Life Insurance Campanies and products.

Description: A discussion of Section 7702 and age 100 insured and the need for guidance on combined annuity and long-term care contracts

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: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

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

Description: Notice 2004-611 is the latest in a series of administrative pronouncements from the Internal Revenue Service related to the appropriate mortality assumptions to be used in computing the definitional limitations under Internal Revenue Code Section 7702 and the seven-pay limitation under the Section 7702A modified endowment rules.