Description: Article describes the current and possible future implications of the recent extension of several tax provisions applicable to insurance controlled foreign corporations

Description: The article suggests that the case of State Farm Mutual Automobile Ins. Co. v. Commissioner, 698 F.3d 357 (7th Cir. 2012), and INT 03-17 may support the argument that estimated extra-contractual obligations are deductible by life insurance companies

Description: Analysis of a private letter ruling addressing a section 807(f) change in basis for computing life insurance reserves.

Description: On June 10, 2016, the Taxation Section hosted a webcast entitled “Federal Income Tax Issues Every Company Must Consider under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through an exploration of the many potential tax issues and areas of interpretation that will arise once principle-based reserves (PBR) becomes the new statutory financial reporting regime for life insurance contracts. This brief article recaps the webcast and provides an update on continuing PBR adoption activity.

Description: A brief summary of these repealed provisions and associated transition rules follows.

Description: The article summarizes Executive Orders from early in the Trump Administration that could affect the ability of IRS to publish tax guidance.

Description: Discussions on CIGNA, SEPP failure, investor control, tacking rule, and split-dollar life insurance arrangement are featured.

Description: Discusses the CCA 201939003 and the conclusions that were made and the impacts it has on a taxpayer's ability to make an election for determining the interest rate used to compute tax-deductible life insurance reserves.

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 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.