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: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

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

Description: The Taxing Times Editorial Board acknowledges the invaluable contributions of our colleague, Art Schneider, who passed away in August. Throughout his career as a tax accountant, Art generously shared his time and talents to help actuaries and other tax professionals increase their understanding of insurance industry tax topics. We will miss him.

Description: The article provides a summary of the 2017 Tax CUts and Jobs Act provisions that are most important to life insurance companies.

Description: This article outlines the IRS directive published in July 2014, which provides a safe harbor treatment for variable annuity hedging gains and losses relating to VA contracts issued before Dec. 31, 2009.

Description: SSAP 101 is the new standard which replaces the current temporary guidance set forth under SSAP No. 10R regarding deferred tax assets [DTAs] and Tax Contingency Reserves.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

Description: The article deals with the critique of a technical advice memorandum issued by the IRS. It basically states the author's opinion that, although the conclusion was correct, the reasoning given was inappropriate.

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.