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.

Description: One of the significant tax benefits of a life insurance contract is that, for purposes of determining the taxable amount of proceeds received under the contract on distributions or surrender,the investment in the contract includes the aggregate amount of premiums, unreduced by the cost of insurance provided IRC section 72c. IRS rules net surrender value reserves must be reduced by a YRT reserve credit.

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: Overview of upcoming second edition of book.

Description: This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing tax reserves for pre-2018 tax years for annuity contracts subject to AG43 and VM-21 and life insurance contracts subject to VM-20 Principal Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain spread amounts in some cases to future tax years starting in 2018.

Description: The article provides an introduction to tax accounting for U.S. life insurance companies, with a focus on NAIC statutory accounting concepts. The author discusses permanent and temporary differences, the current tax provision, and deferred tax accounting requirements, including admissibility testing under SSAP No. 101.

Description: This article briefly summarizes the history of the Passive Foreign Investment Company (PFIC) tax regime. Then it provides a detailed description of the PFIC proposed regulations issued in July of 2019.

Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: This article is about papers submitted in response to a Retirement 20/20 call for submission of papers about Tier II retirement systems, i.e. those that are employer-provided retirement benefits that fit between social insurance and private savings.

Description: This article discusses how the SOA exams have changed over the years and the reasons for the changes. The current system focuses on actuarial education, balances examination rigor with educational experience, and uses technology - where appropriate - to facilitate and enhance learning outcomes.