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Taxing Times: Twenty Years of Thought Leadership

By The TAXING TIMES Editorial Board

TAXING TIMES, August 2025

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With this, our final issue of TAXING TIMES he editorial board would like to reflect on the publication's outsized influence in the field of "taxtuarial science" since the publication of its first issue in May 2005, and to acknowledge the hard work of the many authors and editors who have contributed to its success.

In many ways, it is difficult to categorize TAXING TIMES. Has it been a tax publication with an actuarial readership? An actuarial publication with a tax focus? Regardless, TAXING TIMES has done its best to educate both new and experienced actuaries (and everyone in-between) on foundational and emerging tax topics that affect their work. TAXING TIMES has been a unique publication for the SOA because it has been a collaboration of professionals both within and outside the SOA who worked together on highly complex issues and improved the understanding of taxation for actuaries and non-actuaries alike. Each issue also has provided an opportunity for the American Council of Life Insurers (ACLI) to share activity on the industry's regulatory and legislative agenda. Perhaps most rewardingly, TAXING TIMES has served as an important resource to IRS and Treasury personnel who are charged with providing guidance on company and product taxation with actuarial determinations as a starting point.[1]

We are proud of the thoughtful approach that TAXING TIMES has taken through its various categories of articles. In particular, the "In the Beginning" series (John Adney's brainchild), "Subchapter L: Believe it or not" (Peter Winslow's creation), and "TAXING TIMES Tidbits" provided important technical information in formats that were particularly engaging. Much of that work will remain relevant and accessible for years to come. Several "dialogues" over the years exemplified TAXING TIMES’ philosophy, demonstrating how an actuary, tax lawyer, and accountant might approach the same concepts from different perspectives and how their professions overlap.[2] Timely explanations of new legislation (and new IRS guidance) helped the profession process new rules with a particular focus on what is important to an actuary. On a more personal note, TAXING TIMES was a helpful vehicle to introduce government officials and others to the TAXING TIMES readership.[3]

Much of TAXING TIMES’ work will remain relevant, and we hope much of it will remain accessible electronically. Although many of its articles have been impactful, the following come to mind as being particularly durable and will remain important sources of information and background going forward:

  • The entire “In the Beginning ... A Column Devoted to Tax Basics” series is of high quality and remains an excellent starting point for an actuary looking for a basic understanding of tax rules and where they came from. We particularly recommend “In the Beginning ... Tax Accounting and Deferred Taxes for Life Insurance Companies” (October 2019); “In the Beginning ... Why Do Limitations Apply to Owners of Life Insurance Contracts, Particularly COLI?” (June 2019); “In the Beginning ... Why Section 7702 (and 7702A, too)? Some Historical Perspectives” (February 2018); “In the Beginning ... Premiums Paid, Investment in the Contract, and Tax Basis – We Know It When We See It, Right?” (June 2017); “In the Beginning ... Tax DAC” (February 2017).
  • “IRS Releases Long-Awaited Final RMD Regulations and New Proposed Regulations to Implement SECURE 2.0 Provisions” (November 2024) (RMDs remain important to the administration of qualified annuities);
  • “Rightsizing the Floor Interest Rate Rules of Sections 7702 and 7702A” (March 2021) (the most recent amendment to section 7702's actuarial tests was a direct response to a prolonged period of low interest rates);
  • “IRS Provides Important Guidance on Changes in Basis of Computing Reserves under Section 807(f)” (March 2021) (changes in tax basis for computing reserves are an important consideration each time there is a change in NAIC reserve guidance);
  • “Taxation for M&A and Reinsurance, Part 1: Proposed Regulations on Ownership Change Present Issues for Insurance Companies” (June 2020), and “Taxation for M&A and Reinsurance, Part 2: Product Considerations” (December 2020) (actuaries frequently are called upon to lend either their valuation or product testing expertise in the event of a merger, acquisition, or reinsurance of a block of business);
  • “New Regulations Provide Guidance on Computation and Reporting of Reserves” (October 2020) (the most recent guidance under section 807(d) was a response to significant changes made by the Tax Cuts and Jobs Act, and remain central to tax reserve valuation);
  • “IRS Addresses Tax Treatment of Non-Qualified Annuities Issued to Trusts” (October 2020) (a helpful reference outlining many of the interpretational and administrative challenges posed by annuity contracts with non-natural owners);
  • “Proposed Regulations on Reporting Requirements for Transfers for Value of Life Insurance Contracts” (October 2019), and “Final Regulations Under Sections 101 and 6050Y” (February 2020) (the status of a transfer as a reportable policy sale is important to the income on the contract that its owner reports, and actuaries sometimes are called upon to help with those calculations);
  • “Overview of the Tax Cuts and Jobs Act: Major Changes in the Taxation of Life Insurers, and Changes to the Computation of Tax Reserves under P.L. 115- 97” (June 2018) (most of the June 2018 issue was devoted to these and other topics under the 2017 TCJA, and may be relevant to future actuaries);
  • “Deficiency Reserves: The Cicadas of the Life Insurance Industry” (September 2011) (Chris DesRochers' timely article traced the history of deficiency reserves and their treatment for tax purposes at a time when IRS was called upon to address their inclusion in the statutory reserves cap);
  • “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change, and Administration of the “Material Change” Rules: Meeting the Challenge” (Supplement, May 2012) (actuarial testing under sections 7702 and 7702A depends significantly on whether a contract is treated as newly-issued by reason of a change in its provisions);
  • “Actuarial Guideline XLIII: Statutory and Tax Issues” (Supplement, Feb. 2010) (a precursor to VM-21, AG 43 posed significant tax issues that were addressed by industry directive and, ultimately, by an amendment to section 807(d));
  • Supplement on the 2008 IRS revenue procedures for remediating failed life insurance contracts, inadvertent MECs, and inadvertent diversification failures (Supplement, Feb. 2009) (the supplement includes multiple articles covering Rev. Procs. 2008-38, -39, -40, -41, and -42);
  • “Fortuity, Or Not Fortuity? . . . That is the Question” (Supplement, September 2008) (a direct response to Rev. Rul. 2007-47, in which the IRS expanded on the insurance requirement of "fortuity"); and
  • “Evolution of the Mortality Requirements under Sections 7702 and 7702A of the Internal Revenue Code” (May 2005) (authored by Chris DesRochers, the very first article in the very first issue of TAXING TIMES is foundational and remains directly relevant to product taxation in 2025).

We would be remiss not to acknowledge Chris DesRochers[4] for his vision in the creation of TAXING TIMES, Brian King, who was TAXING TIMES’ first editor-in-chief, and Ed Robbins,[5] who served as the Taxation Section's first chair. Likewise, for many years until his death in 2023, Art Schneider[6] contributed faithfully as both an author and an editor, holding us all to the highest standards. Many others, as well, sacrificed their time and effort for the betterment of the profession, and we are indebted.[7]

Most of all, we appreciate the readers of TAXING TIMES, whose feedback over the years has enriched us, and the Society of Actuaries, which provided this valuable platform.[8]


This article is provided for informational and educational purposes only. Neither the Society of Actuaries nor the respective authors’ employers make any endorsement, representation or guarantee with regard to any content, and disclaim any liability in connection with the use or misuse of any information provided herein. This article should not be construed as professional or financial advice. Statements of fact and opinions expressed herein are those of the individual authors and are not necessarily those of the Society of Actuaries or the respective authors’ employers.

Endnotes

[1] The IRS even cited TAXING TIMES in guidance related to safe harbors for applying Internal Revenue Code sections 7702 and 7702A to life insurance contracts that mature after age 100. See Notice 2009-47, 2009-24 IRB 1083, Section 2.08; Rev. Proc. 2010-28, 2010-34 IRB 270, Section 2.09; and Rev. Proc. 2018-20, 2018-11 IRB 427, Section 2.09.

[2] “Accountant/Tax Attorney Dialogue on the History and Purpose of Internal Revenue Code Section 811(a)” (October 2018); “Actuary/Accountant/Tax Attorney Dialogue on Internal Revenue Code Deference to the NAIC Part I: Tax Reserves” (June 2015); “Actuary/Accountant/Tax Attorney Dialogue on Internal Revenue Code Deference to NAIC: Part II: Policyholder Tax Issues” (October 2015); “Accountant/Tax Attorney Dialogue on Internal Revenue Code Deference to NAIC: Part III: Insurance Classification Tax Issues” (March 2016); “Actuary/Accountant/Tax Attorney Dialogue on Notice 2013-19 and the Statutory Reserves Cap” (October 2013); “Accountant/Tax Attorney Dialogue on Internal Revenue Code Deference to NAIC: Part IV: Insurance Tax Accounting Issues” (June 2016); “Attorney-Actuary Dialogue on Notice 2010-29” (September 2010); “Actuary/Tax Attorney Dialogue on Selected Tax Issues in Principles-Based Reserves Subject to CRVM” (February 2007); “Actuary/Tax Attorney Dialogue on Selected Tax Issues in Principles-Based Reserves (Part II)” (May 2007); “Tax Attorney and Tax Actuary Dialogue on IRS Notice 2008-18 - AG VACARVM and Life PBR (Part III)” (March 2008); “Actuary/Tax Attorney Dialogue on Selected Tax Issues in Principle Based Reserves (Part IV)” (February 2013).
[3] “Meet Alexis MacIvor, New Chief of the Insurance Branch” (March 2016); “The Road to Tax Reform: An Interview with Chairman Dave Camp” (October 2015); “Welcome, Helen Hubbard” (May 2014); “Conversation with Sheryl Flum” (October 2013); “Inside the IRS: An Interview with William J. Wilkins” (February 2010); “Getting to Know Walter Welsh” (May 2008).
[4] “A Tribute to Christian DesRochers” (October 2013).
[5] “In Memoriam Edward L. Robbins, Jan. 2, 1940–Dec. 28, 2020” (August 2021).
[6] “Remembering Art Schneider” (October 2023).
[7] Over the years, roughly two dozen individuals have served on the editorial board: John Adney, Ernie Achtien, Kushagra Agrawal, Jean Baxley, Ann Cammack, Mary Elizabeth Caramagno, Mayowa Dauda, Christine Del Vaglio, Chris DesRochers, Sheryl Flum, Rick Gelfond, Brian King, Larry Hersh, Sam Mitchell, Kristin Norberg, Kory Olsen, Lori Robbins, Art Schneider, Bruce Schobel, Mark Smith, Craig Springfield, Jeffrey Stabach, Greg Stephenson, Dan Stringham, Jim Van Etten and Peter Winslow. Many of these editors also authored multiple articles, as did other authors too numerous to mention (though Ed Robbins, Richard Bush and Bryan Keene contributed particularly deep technical articles that will never be forgotten).
[8] Numerous SOA staff members have supported TAXING TIMES over the years. We are especially grateful for the copyediting support provided by Jacque Kirkwood and Kathryn Baker, especially for the extra effort required when legislation, regulations or other developments demanded lengthy issues or supplements.