Description: This article discusses Internal Revue Code, ‘IRC,’ Sections 7702 and 7702A with respect to the implementation of the 2001 CSO Mortality Table, which must be used in the calculations for policies issued on or after January 1, 2006. “The insurance industry has requested guidance from the Treasury Department and the Internal Revenue Service on the proper application of the current computational rules to the 2001 CSO Mortality Table but, to date, such guidance has not been provided. Therefore, the Taxation Section established the 2001 CSO Maturity Age Task Force, the members of which authored this article, to propose methodologies that would be actuarially acceptable under Sections 7702 and 7702A of the Code for calculations under contracts that do not provide for actual maturity before age 100.” This article summarizes the task force recommendations.

Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.

Description: Discusses how companies must ensure that significant and necessary product development, and administrative and compliance system changes, have been completed and tested in time to accommodate new requirements.

Description: September 2008 full issue of the Taxation Section newsletter, Taxing Times.

Description: This article is a general discussion about earnings rates and toll charges and how to compute them.

Description: This article is a general discussion about prior correction procedures for failed life insurance contracts and the new IRS procedure for remediation.

Description: This editorial highlights the peer review process that all articles in the newsletter go through.

Description: February 2010 issue of the Taxation Section newsletter, Taxing Times

Description: The financial crisis of the recent past has prompted the director of the financial services industry portion of the Large and Mid-Size Business “LMSB” Division of the Internal Revenue Service “Service” to announce an increased focus during audit on the reporting by members of the financial services industry of losses attributable to bad debts or to worthless securities issued by subsidiaries.

Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.