Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

Description: TAXING TIMES recently sat down with a group of retired tax actuaries to hear about how they got involved in actuarial tax matters and how their tax experience impacted their careers. Their insights will be useful for actuaries who are just starting out in the profession, as well as more seasoned actuaries.

Description: This article discusses the guidance provided in IRS Notice 2022-6 and prior guidance on whether distributions from an individual account under a qualified retirement plan satisfy the exception to the 10 percent additional tax in Internal Revenue Code section 72(t) for certain substantially equal periodic payments.

Description: This article outlines how Bermuda advanced in global tax compliance through the enactment of the Bermuda Corporate Income Tax (CIT) Act of 2023, which will take effect for tax years beginning on or after January 1, 2025. The Bermuda CIT rules incorporate key foundational definitions from the Organization for Economic Cooperation and Development’s (OECD) Pillar Two GloBE model rules, while also exhibiting significant differences from Pillar Two. The article discusses the various elections available for taxpayers, key mechanics of the CIT, and the latest administrative guidance released by the Government of Bermuda.