Description: The presenters will discuss recent developments related to the federal qualification and taxation of life insurance and annuity contracts. Among other topics, there will be a focus on comparing and contrasting life insurance product qualification in the U.S. under IRC sections 7702 and 7702A versus qualification in Canada under the 'exempt test' of the Income Tax Act, which has been revised in recent years. Discussion will include comparisons of Canadian provisions to U.S. definition of life insurance and Modified Endowment Contract concepts.

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

Description: On June 26, 2013, the Supreme Court released its decision in the case of United States v. Windsor, Executor of the Estate of Spyer, et al. addressing the constitutionality of the federal Defense of Marriage Act (“DOMA”). This article explores the implications for life insurance and annuity contract spousal provisions that are governed by federal law.

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: This 2008 supplement addresses the issues that have arisen in life insurance tax laws related to IRC 7702 and 7702A since the book was published in 2004. It also enhances and clarifies issues that were addressed in the text, adding detail and further discussion.

Description: This article summarizes IRS guidance on what constitutes a change in basis for computing life insurance reserves under the Internal Revenue Code.

Description: SECURE 2.0 included provisions that improve the ability of insurers to serve those who own qualified annuities. Several previously disallowed distribution methods are now allowed. These changes should increase the availability and desirability by contract owners to choose a payout annuity compared to required minimum distributions. An insurer considering enhancing qualified annuitization offerings might follow the approach outlined to potentially increase qualified annuitization sales and assist contract owners in protecting their principal more directly than previously.

Description: Read the June 2016 issue of Taxing Times.