From the February 2018 Taxing Times: This edition of “In the Beginning” provides a history of IRC Sections 7702 and 7702A and the justification for their existence. Written by John T. Adney.  Read by Dan Theodore.

Direct download: WhySection7702and7702A_Feb2018TT.mp3
Category:Taxation -- posted at: 7:50am CST

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

In September 2015, the Tax Court issued its opinion blessing residual value insurance contracts as “insurance” for federal income tax purposes. Authors Jean Baxley and Sheryl Flum provide a brief backdrop to the “what is insurance” issue, summarize the Tax Court’s opinion in RVI, and offer observations regarding some of the potential implications of the decision.  From the March 2016 Taxing Times.  Read by Dan Theodore.

Direct download: TTMar2016_RVI_v_Commissioner.mp3
Category:Taxation -- posted at: 12:41pm CST

Dan Theodore reads "In The Beginning…A Column Devoted to Tax Basics – How Are Nonqualified Annuities Taxed?" from the March 2016 issue of Taxing Times written By John T. Adney.

Direct download: TTMarch2016_ITB_NQAnnuities.mp3
Category:Taxation -- posted at: 10:26am CST

Dan Theodore reads "A Tax Like No Other: The Health Insurer Fee" from the October 2015 issue of Taxing Times written By Jean Baxley, Mersini Keller and Lori Robbins.

Direct download: TTOct2015_A_Tax_Like_No_Other_32.mp3
Category:Taxation -- posted at: 10:51am CST

Dan Theodore reads "In The Beginning…A Column Devoted To Tax Basics - Qualifications of Life Insurance Contracts Under the Internal Revenue Code" from the October 2015 issue of Taxing Times written by Brian King, John Adney and Craig Springfield.

 

Direct download: InTheBeginningOct2015.mp3
Category:Taxation -- posted at: 10:21am CST

Dan Theodore reads "The Taxable Deferred Annuity With Guaranteed Lifetime Withdrawals" from the October 2015 issue of Taxing Times written by Bryan W. Keene.

Direct download: TaxingTimes_Oct2015_TibBit2_FM.mp3
Category:Taxation -- posted at: 10:19am CST

Dan Theodore reads "Proposed Regulations Targeting Hedge Fund Reinsurance Arrangements May Impact Traditional Insurance Companies" from the October 2015 issue of Taxing Times written by Brion D. Graber.

Direct download: TTOct2015_Tidbits1.mp3
Category:Taxation -- posted at: 10:17am CST

Dan Theodore reads "In The Beginning…A Column Devoted To Tax Basics - Consequences Of Insurance Business Or Company Acquisitions” from the June 2015 issue of Taxing Times written by Gary R. Vogel and Kristie Khaw.

Direct download: In_The_Beginning_TT_June_2015_64_Final.mp3
Category:Taxation -- posted at: 10:15am CST

Dan Theodore reads “Private Letter Ruling on Section 807(f) Refines Change-in-Basis Rule" from the June 2015 issue of Taxing Times written by Craig Pichette and Sheryl Flum.

 

 

Direct download: Change_In_Basis_TT_June2015.mp3
Category:Taxation -- posted at: 10:14am CST

Dan Theodore reads “IRS and Treasury Release 2014-2015 Priority Guidance Plan” from the February 2015 issue of Taxing Times written by Robert A. Shanahan and Mark S. Smith.

Direct download: IRS2014-2015Plan_Feb2015TT.mp3
Category:Taxation -- posted at: 2:05pm CST

Dan Theodore reads “In the Beginning…Tax Accounting for Insurance Companies” from the February 2015 issue of Taxing Times written by Stephen R. Baker.

 

Direct download: TaxAccountingInTheBeginning_Feb2015TT.mp3
Category:Taxation -- posted at: 2:03pm CST

Listen in as Dan Theodore reads “IRS Approves the Annuity Treatment for Term Certain Variable Payout”, which was featured in the October 2014, Taxing Times written by John T. Adney.  

Direct download: AnnTreatmentForTermCertVarPayout_Oct2014.mp3
Category:Taxation -- posted at: 3:34pm CST

Listen in as Dan Theodore reads “Revenue Ruling 2014-15:  The Requirement Risk Distribution, The Law of Unintended Consequences and New Questions to Consider in Funding Retiree Health Benefits” which was featured in the October 2014, Taxing Times written by Terrance F. Richardson and Mark S. Smith.

Direct download: RevRul2014-15_TT_Oct1014.mp3
Category:Taxation -- posted at: 3:32pm CST

Listen in as Dan Theodore reads “Chairman Camp’s Tax Reform Discussion Draft:  What Does It Mean to the Life Insurance Industry” written by Brion Graber and Peter Winslow.  This article was featured in the October 2014, Taxing Times Supplement.

Direct download: ChaimanDraftTaxReform_Oct2014Supp_64.mp3
Category:Taxation -- posted at: 3:30pm CST

Last January, the Tax Court decided Rent-A-Center, Inc. and Affiliated Subsidiaries v. Commissioner, involving a captive insurance arrangement that was challenged by the Internal Revenue Service (IRS). The Tax Court found that a parental agreement between a captive and its parent could be present in a valid insurance arrangement for federal income tax purposes.

Direct download: RentACenter_from_Taxing_Times.mp3
Category:Taxation -- posted at: 9:43am CST

This column—the first in a series intended to provide basic education on the federal tax law, with a focus on the rules applicable to life insurance products and companies—spells out in brief the hierarchy of authorities that establish and interpret that body of law.

Direct download: SourcesOfFederalTaxLaw.mp3
Category:Taxation -- posted at: 9:59am CST

In the case of United States v. Windsor, the Supreme Court addressed the constitutionality of the Federal Defense of Marriage Act2 (“DOMA”) in a situation involving a claim for refund of federal estate taxes.  This article considers guidance addressing the federal government’s response to the Windsor decision.

Direct download: Post-Windsor_Guidance.mp3
Category:Taxation -- posted at: 9:50am CST

For many decades, the staff of the Joint Committee on Taxation of the U.S. Congress has prepared a summary, at or near the end of a congressional session, of significant tax legislation enacted during that session. This summary, officially known as a “General Explanation” and more commonly called the “Blue Book” because it is enclosed within blue covers.  Recently, the Supreme Court of the United States had occasion to consider just what official credence should be accorded to Blue Books.

 

 

Direct download: BlueBookBlues_May2014.mp3
Category:Taxation -- posted at: 9:47am CST

2012-2013 Priority Guidance Plan - What's In it for Life Insurance Companies:  from the May 2013 Taxing Times, this article looks at the issues that the IRS plans to address in the coming year, focusing on those that affect the Life Insurance Industry.  The article was written by Susan J. Hotine and is read by Dan Theodore.

Direct download: 2012-13PriorityGuidancePlanMay2013PodcastA.mp3
Category:Taxation -- posted at: 1:48pm CST

From the May 2013 issue of Taxing Times, authors By Walter Welsh, Mandana Parsazad and Pete Bautz present  “ACLI UPDATE - DEFICIENCY RESERVE GUIDANCE”, read by Dan Theodore.

Direct download: ACLI_Update_May2013_Podcast.mp3
Category:Taxation -- posted at: 10:37am CST

In this podcast, Dan Theodore reads from the article by John T. Adney and Craig R. Springfield entitled “The Perils of Reducing Death Benefits: Private Letter Ruling 201230009” that appears the February 2013 issue of Taxing Times.

Direct download: Taxation_PerilsofReducingDB_FINAL.mp3
Category:Taxation -- posted at: 2:51pm CST

In this episode, Dan Theodore reads from “CIGNA Update – Much Ado About Nothing” by Peter H. Winslow. This article appears in an issue of Taxing Times.

Direct download: SOAPodcastCIGNAUpdateFINAL.mp3
Category:Taxation -- posted at: 9:21am CST

In this episode, Dan Theodore reads from and summarizes "Recent Developments on Policyholder Dividend Accruals" from the May 2012 issue of Taxing Times.

Direct download: DividendAccrualsPodCast.mp3
Category:Taxation -- posted at: 2:49pm CST

In this episode, Dan Theodore reads from and summarizes "Life Settlements: Congress Wades Into The Fray" from the October 2012 issue of Taxing Times.

Direct download: LifeSettlementsPodcast_64kps.mp3
Category:Taxation -- posted at: 10:48am CST

This podcast gives a brief synopsis of articles in the February 2012 issue of the Taxing Times newsletter.

Direct download: WhatsInTaxingTimesPodcastFinal_629.mp3
Category:Taxation -- posted at: 11:12am CST

The authors of the "Partial Exchange Keeps Improving" article from the February 2012 issue of the Taxing Times Newsletter discuss key points of this important topic.

Direct download: Partial_Exchange_Podcast.mp3
Category:Taxation -- posted at: 11:09am CST

Listen to Chairperson Kristin Schaefer as she discusses her column "From the Chair" in May 2012 issue of the Taxing Times Newsletter.

Direct download: FromTheChairMay2012.mp3
Category:Taxation -- posted at: 11:04am CST

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