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: 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: This dialogue discusses the history and purpose of section 811(a) and its historic role in the computation of life insurance company taxable income and, in particular, reserves.

Description: Company Tax Issues

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: With the growth in SOA podcasts over recent years, here’s your chance to be part of the “live studio audience” for an upcoming podcast release. Inspired by The Social and The View, join us in our talk show setting as we discuss current and emerging topics in the actuarial profession, with incoming SOA President Andy Rallis as one of the many guests we’ll bring to the stage just after Tuesday’s Presidential Luncheon. This rapid-fire session will incorporate audience participation, opportunities to be part of the podcast during question-and-answer sessions and highlight new SOA section, research and education activities. Stay tuned after the meeting to listen in to the session through SOA podcast feeds.

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

Description: Explore a brief overview of federal income taxation of health insurers and selected technical tax topics during this panel discussion webcast. You'll dive into the evolution of heath insurers and healthcare-related services and the arising questions regarding their risk-bearing activities, as well as whether or not certain types of healthcare businesses qualify as "insurance companies" for federal income tax purposes. Also, expect to learn about loss reserves for guaranteed renewable contracts and how they can affect insurance company tax status. This webcast will continue to highlight how the IRS challenges loss reserves of health insurers as the panelists review the status of tax cases, IRS guidance and recent IRS activity regarding "margins."

Description: Mark Smith interviews Helen Hubbard, associate chief counsel (Financial Institutions and Products) in the IRS Office of Chief Counsel.