Description: This session discussion is about what practitioners have been doing with the new Internal Revenue Code Section 410b and Section 401a26, how have they been doing and comparability calculations for the above. From Record of the Society of Actuaries Vol. 15, No. 1.

Description: 1992 SOA Regional Meeting, Chicago. This presentation provided a 1992 rulings and regulations update including: 1. Bankruptcy. 2. Pension Benefit Guarantee Corporation update. 3. IRS Announcement 92-29, which extended the effective dates for the 401 a4 and related regulations. 4. IRS Announcement 92-81, which is is the data procedure announcement for 401a4 substantiation. 5. Revenue Procedure 92-42, which, repeals Revenue Procedure 89-45. 6. The Internal Revenue Service business plan.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. The panelists present the basics of nondiscrimination in pension plans, the provisions of the tax code designed to prevent benefits and contributions from being steered primarily to the higher paid participants in a plan. The panelists discuss the relevant sections of the Internal Revenue Code, including 401[a][4], 410[b], 401[I], 401[a][26], and the recently published regulations. From the Record of Society of Actuaries, Volume 17, No. 4B.

Description: This paper examined two interrelated aspects of federal income taxation of life insurance companies. First, a common-sense approach to the Life Insurance Company Income Tax Act of 1959 was developed. Second, marginal tax rates for Phase III companies was developed.

Description: This is an article about how to place value on an annuity benefit.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

Description: A discussion of the tax-related initiatives listed on the IRS Priority Business Plan for 2010 targeting product tax issues and how they relate to the work of the Taxation Section.