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Federal Income Taxation of Life Insurance Companies

Federal Income Taxation of Life Insurance Companies

Provides comprehensive analysis of the special taxprovisions that apply to life insurance companies.


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    Written by Ernst & Young partners, Federal Income Taxation of Life Insurance Companies provides comprehensive analysis of the special tax provisions that apply to life insurance companies. The 36 chapters examine special areas in taxation of life insurance companies, corporate reorganizations involving life insurance companies, taxable acquisitions of life insurance companies, taxation of foreign life insurance companies and foreign branches of U.S. life insurance companies, and much more. Key features and recent updates include:

    • The most recent legislative changes and IRS rulings
    • Tax-planning suggestions
    • Hypothetical examples
    • Analysis of the adoption by the National Association of Insurance Commissioners ("NAIC") of Actuarial Guidelines 43 and the tax implications of Actuarial Guideline 43
    • Discussion of the safe harbor addressing the application of IRC Sections 7702 and 7702A to life insurance contracts that may continue in force after the insured individual attains age 100
    • Expanded discussion of failed life insurance contracts, including corrections of errors, waivers and closing agreements
    • Comprehensive discussion of the taxation of life settlements
    • Analysis of the IRS application of IRC § 845(b) to reinsurance transactions
    • Addition of the legislative and regulatory history of Section 381(c)(22)
    • Discussion of the election to extend the carryback period for a life insurance company's loss from operations.

    First published in 1983.

    3 Volumes; Loose-leaf; updated annually.

    VOLUME 1

    PART I: OVERVIEW AND HISTORY

    Chapter 1: Introduction
    Chapter 2: Overview of Life Insurance Company Taxation
    Chapter 3: History of the Taxation of Life Insurance Companies

    PART II: DEFINITION OF A LIFE INSURANCE COMPANY AND LIFE INSURANCE RESERVES

    Chapter 4: Definition of a Life Insurance Company
    Chapter 5: Life Insurance Reserves--Basics
    Chapter 6: Life Insurance Reserves-Tax Treatment
    Chapter 6A: Computation of Tax Reserves

    PART III: SYSTEM OF TAXATION OF LIFE INSURANCE COMPANIES

    Chapter 7: Tax Rates and Tax Credits
    Chapter 8: Life Insurance Company Taxable Income
    Chapter 9: Small Life Insurance Company Deduction
    Chapter 9A: Differential Earnings Amount for Mutual Life Insurance Companies
    Chapter 10: Proration
    Chapter 11: Shareholders and Policyholders Surplus Accounts (Phase III)

    PART IV: SPECIAL AREAS IN TAXATION OF LIFE INSURANCE COMPANIES

    Chapter 12: Operations Loss Deduction
    Chapter 13: Capital Gains and Losses
    Chapter 14: Reinsurance
    Chapter 15: Accounting Methods
    Chapter 16: Consolidated Returns
    Chapter 17: Variable Contracts and Separate Accounts
    Chapter 18: Taxation of Foreign Life Insurance Companies and Foreign Branches of U.S. Life Insurance Companies
    Chapter 19: Reserved

    VOLUME 2

    PART V: CORPORATE REORGANIZATIONS INVOLVING LIFE INSURANCE COMPANIES

    Chapter 20: Corporate Reorganizations?Overview
    Chapter 21: Acquisitive Reorganizations
    Chapter 22: Type D Reorganizations and Corporate Divisions
    Chapter 23: Type E and Type F Reorganizations
    Chapter 24: Save the Charter Transactions
    Chapter 25: Corporate Formations
    Chapter 26: Holding Company Formation and Termination
    Chapter 27: Carryovers in Tax-Free Reorganizations
    Chapters 28-29: Reserved

    PART VI: TAXABLE ACQUISITIONS OF LIFE INSURANCE COMPANIES

    Chapter 30: General Considerations in Taxable Acquisition of Life Insurance Company
    Chapter 31: IRC Sections 338 and 338(h)(10) Elections
    Chapters 32-39: Reserved

    PART VII: TAXATION OF POLICYHOLDER

    Chapters 40-45: Reserved
    Chapter 46: Life Insurance Contracts and Policyholder Taxation
    Chapter 47: Annuities and Policyholder Taxation

    PART VIII: NEW PRODUCTS

    Chapter 48: Recent Developments in Life Insurance Products
    Chapter 49: Reserved

    PART IX: REPEALED LAW

    Chapter 50: Taxable Investment Income (Phase I) and Gain or Loss From Operations (Phase II) Under the 1959 Act
    Chapter 51: Consolidated Returns (Old Law)
    Chapter 52: Computation of Tax Reserves (Old Law)
    Glossary
    Table of Cases
    Table of Statutes and Regulations
    Index

    VOLUME 3

    Appendix I: Revenue Rulings
    Appendix II: Revenue Procedures
    Appendix III: Letter Rulings

     

    Terry Jacobs


    Terry Jacobs is a partner in National Tax at Ernst & Young's Washington, DC, office and is the global insurance tax leader. He has a BBA and MA in Accounting and a JD and LLM in Tax.

     

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