Description: A discussion of the development, key elements, applications, and implementation process of the 2001 CSO Tables for individual life insurance policies for computing minimum reserves, nonforfeiture benefits and tax reserves.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are required in different states.

Description: This article details proposed regulations issued by the IRS that clarify that a single series may be treated as an entity separate from a series organization for federal income tax purposes, even if it is not recognized as a separate entity under local law.

Description: Discusses of the application of disproportionate asset acquisition rules under the life/nonlife regulations. How the amount of premiums or reserves should be measured is also discussed in detail.

Description: A discussion of the bill that will require tax reporting of sales of interests in life insurance policies. This bill will require the buyer of an interest in a life insurance policy to report the sale to the Internal Revenue Service and notify the life insurer that issued the policy.

Description: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: The article describes the IRS Industry Issue Resolution (IIR) process as applied to the Insurance Industry's Bad Debt Issue. The article describes the IRR process in general, how that process was applied to the bad debt issue, and the safe harbor approach available for insurance companies. The safe harbor is described in LB&I Commissioner Heather Maloy's Directive dated July 30, 2012 (LB&I-4-0712-009).

Description: An interview with Sheryl Flum, chief, Branch 4, IRS Office of Associate Chief Counsel (Financial Institutions and Products) at the Internal Revenue Service, regarding her role at the IRS and current tax issues facing the life insurance industry.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.