Description: On April 24, 2015, Treasury and the Internal Revenue Service (IRS) published proposed regulations (REG-108214-15) that provide guidance regarding when a foreign insurance company’s income is excluded from the definition of passive income under Section 1297(b)(2)(B). The proposed regulations are directed at hedge funds that purport to establish a foreign reinsurance company in an effort to avoid treatment as a passive foreign investment company (PFIC), but could have unintended consequences for traditional insurance companies.

Description: The Tidbit summarizes LTRs 201609008 and 201613016 and discusses the definition of insurance under the tax code in light of these new pieces of guidance from the IRS.

Description: This article discusses the complexities of such a simple statement as well as highlight certain differences between tax and book treatment of that capitalization.

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

Description: Update on accounting and capital/RBC issues subsequent to tax reform.

Description: Read the October 2019 issue of Taxing Times, published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Update from ACLI on tax issues of interest

Description: The article discusses recently-issued regulations under section 807 of the Internal Revenue Code, concerning the computation and reporting of reserves. The provisions addressed generally relate to the Tax Cuts and Jobs Act of 2017.

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: This article outlines how Bermuda advanced in global tax compliance through the enactment of the Bermuda Corporate Income Tax (CIT) Act of 2023, which will take effect for tax years beginning on or after January 1, 2025. The Bermuda CIT rules incorporate key foundational definitions from the Organization for Economic Cooperation and Development’s (OECD) Pillar Two GloBE model rules, while also exhibiting significant differences from Pillar Two. The article discusses the various elections available for taxpayers, key mechanics of the CIT, and the latest administrative guidance released by the Government of Bermuda.