From the October 2017 Taxing Times: This edition of “In the Beginning” provides a high-level overview of reinsurance: its purpose and uses, its different forms, and the tax results and issues that can arise in reinsurance transactions. Written by Jean Baxley and Eli Katz.  Read by Dan Theodore.

Direct download: TTOct2017_TaxingReinsurance.mp3
Category:Taxation -- posted at: 8:03am CST

From the June 2017 Taxing Times:  The IRS has consistently spoken to the doctrine of investor control through private letter ruling requested by insurers and fund managers. And within the past decade, many of those requests, and the rulings issued in response, dealt with the concern that indirect investment in publicly-available funds could, depending on the structure employed, fall on the wrong side of the doctrine. Three recent private letter rulings, the subject of this article, represent a continuation of this trend.  Written by John T. Adney and Bryan W. Keene.  Read by Dan Theodore.

Direct download: TT_June2017_InvestorControl.mp3
Category:Taxation -- posted at: 10:00am CST

From the June 2017 Taxing Times: The federal income tax law was once described by a federal judge as a conspiracy in restraint of understanding. While people—including tax professionals—at times feel that way, there are some terms in the tax law that appear reassuringly simple. And yet some of those terms are deceptively simple. This edition of the “In the Beginning” column devotes itself to exploring, at a basic level, the tax meaning of three concepts that are fundamental to the income taxation of life insurance products: premiums paid, investment in the contract, and basis. Written by John T. Adney.  Read by Dan Theodore.

Direct download: TT_June1017_InTheBeginning.mp3
Category:Taxation -- posted at: 10:40am CST

From the June 2017 Taxing Times: The federal income tax law was once described by a federal judge as a conspiracy in restraint of understanding. While people—including tax professionals—at times feel that way, there are some terms in the tax law that appear reassuringly simple. And yet some of those terms are deceptively simple. This edition of the “In the Beginning” column devotes itself to exploring, at a basic level, the tax meaning of three concepts that are fundamental to the income taxation of life insurance products: premiums paid, investment in the contract, and basis. Written by John T. Adney.  Read by Dan Theodore.

Direct download: TT_June1017_InTheBeginning.mp3
Category:Taxation -- posted at: 10:40am CST

Tax and statutory accounting changes present complex legal questions and challenges in product development and financial reporting, underscoring the importance of collaboration between actuarial, financial and legal departments. To get perspective on best practices for tax actuaries collaborating with accountants and lawyers, we interviewed three representative tax leaders who included the chief tax officer (CTO), chief tax actuary, and chief tax counsel from three major U.S. insurance companies. From the February 2017 Taxing Times. Written by Sheryl Flum, Rena Kuliyeva and Jacqueline Yang.  Read by Dan Theodore.

Direct download: TTFeb2017BestPracticesCollaboration.mp3
Category:Taxation -- posted at: 11:25am CST

The IRS recently released Notice 2016-631 providing safe harbor guidance for use of the 2017 CSO in calculations under sections 7702 and 7702A. This article contains a summary which many actuaries will find quite helpful. Written by John T. Adney, Craig Springfield and Brian King. Read by Dan Theodore.

Direct download: TTFeb2017IRS2016-63SafeHarborGuidance.mp3
Category:Taxation -- posted at: 3:20pm CST

Tax Section: Product Tax Implications of the Adoption of the 2017 CSO Tables

This article is part one of a two part series addressing product tax implications of the adoption of the 2017 CSO Tables. Part 1 describes the mortality requirements of sections 7702 and 7702A​. From the October 2016 Taxing Times. Written by John T. Adney, Craig Springfield and Brian King. Read by Dan Theodore, FSA, MAAA.

Direct download: TT_Oct2016_2017_CSO_Part_1_32kbps_10Dec2016.mp3
Category:Taxation -- posted at: 4:16pm CST

The Insurance Branch in IRS Chief Counsel’s National Office recently issued a Chief Counsel Advice (CCA) memorandum regarding the Dividends Received Deduction in the separate account partnership fund context.  The conclusions reached in the CCA constituted a victory of significance for the taxpayer involved, and while not constituting precedent, should benefit other life insurance companies in comparable situations.   From the June 2016 Taxing Times.   Written by Samuel A. Mitchell and John T. Adney.  Read by Dan Theodore, FSA, MAAA.

Direct download: TT_June_2016_DRD_Guidance.mp3
Category:Taxation -- posted at: 9:25am CST

The treatment of foreign operations U.S. tax purposes is complex, and the addition of the insurance component adds to the complexity.  This article will give the listener an introduction to the treatment of wholly owned foreign insurance company subsidiaries of US insurers.  From the June 2016 Taxing Times. Written by Tim Branch.  Read by Dan Theodore.

Direct download: InTheBeginning_ForeignInsOps__June2016.mp3
Category:Taxation -- posted at: 2:27pm CST

Since the 1970’s, taxpayers purchasing and selling variable life insurance and annuity contracts have been wary of the “Investor Control Doctrine.”  Authors Ann Cammack and Frederic J. Gelfond provide a lively presentation of the history and issues.  From the March 2016 Taxing Times.  Read by Dan Theodore.

Direct download: TTMar2016_InvestorControl_1.mp3
Category:Taxation -- posted at: 3:12pm CST