Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

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: This is an article about how to place value on an annuity benefit.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: Discusses why it is so important for actuaries to actively monitor evolving issues with taxation of life insurance companies and products, and how to monitor the issues and get involved with the process.

Description: Almost 65 years ago, the Supreme Court issued its opinion in Helvering v. Le Gierse, addressing when an arrangement should be recognized as involving “insurance” for federal income tax purposes. According to the Court, an “insurance risk” must be present, and for an insurance risk to exist, there must be “risk-shifting and risk distribution.”

Description: This article discusses the temporary waiver and how it provides only limited relief from the section 401a9 minimum distribution requirements.