Insurance tax services

PwC is one of the world's largest providers of tax-related services to the insurance industry. Our Insurance Tax Services Practice helps clients with tax compliance, refinement of tax structures, and implementation of tax-planning strategies.

Our key insurance tax services include:

Multi-state

Our insurance state and local tax (SALT) professionals provide coordinated services for state and local tax planning and help insurers identify and implement tax-planning opportunities. We also provide assistance to insurers to help resolve their issues with state taxing authorities on premium tax issues as well as issues on other state or local taxes.

International

Our international insurance professionals provide a range of services to both outbound and inbound clients. Our outbound service offerings include foreign tax credit analysis, Subpart F planning, tax efficient cross-border financing, and assistance in setting up and running overseas operations. Our inbound services include permanent establishment analysis, financing strategies, and assistance in connection with mergers and acquisitions. In addition, we provide assistance with applications for Section 953(d) elections, excise tax-closing agreements, and transfer pricing studies and documentation.

Information reporting

We help insurers navigate IRS reporting and withholding obligations associated with various types of payments, including those related to insurance products, deferred compensation, and commissions, as well as the complicated reporting requirements associated with attorney payments. This group also evaluates client systems and procedures, and advises them regarding the abatement of proposed penalties associated with information returns and failures to properly deposit withheld tax.

Risk management

We work with clients to evaluate alternatives for their risk management programs and assist them in the implementation of the chosen solution. We evaluate current programs and design alternative structures for deductibles, attachment points and aggregate stop-losses taking into account market risk-transfer price alternatives.

Tax accounting

The continuous developments related to financial and tax reporting require tax practitioners to work closely with financial reporting staff to insure proper reported. For our non-audit clients, PwC's tax provision services helps taxpayers with preparaing their tax accruals, or other related projects, such as an analysis of tax positions at quarter/year-end, and/or deferred tax reviews.

Mergers and acquisitions

From strategic deal planning and structuring to due diligence and post deal integration, our insurance M&A team provides creative solutions to insurance tax problems inherent in reorganizations, reinsurance transactions, spin-offs, dispositions, public offerings, and capital issues, such as demutualizations, and the formation of mutual holding companies. More specifically, we assist insurers with foreign and domestic acquisition planning, restructuring corporate entities, basis studies, analyses of stock versus asset acquisitions, liquidations, and life/non-life consolidated return issues.

Transfer pricing

Our global network of insurance transfer pricing specialists have expertise in every aspect of inter-company pricing, including pricing structure planning, documentation compliance, and controversy resolution. We assist clients with national and state and local tax transfer pricing issues. We use advanced technology for internal information and knowledge sharing, as well as project completion, and offer our clients these tools when appropriate.

Captive insurance companies

PwC provides a broad range of services to captive insurance companies. We serve many pre-eminent industrial and financial services organizations in the US and around the world. Our multi-disciplinary approach includes experienced tax, actuarial, risk management, accounting, regulatory and business recovery professionals who help insurers quickly identify, plan and address business issues, opportunities and challenges, and reduce last minute surprises.

Our services mirror business cycle needs, including:

  • Establishment – Formation assistance, captive tax planning, structuring and feasibility studies.
  • Enhancement – Risk management, tax and operational reviews of existing and planned programs, including "Captive Health Checks" of existing captives.
  • Ongoing maintenance – Audit and assurance services, actuarial reserve studies and statutory certifications, tax compliance and actuarial support for transfer pricing analyses.
  • Closure – Process improvement reviews, professional advice on run-off or commutation strategies (including managed wind-ups).

Employee benefits

We can evaluate insurers’ qualified pension, retirement and welfare benefits plans, and assess and develop nonqualified deferred compensation programs. Moreover, we provide support to clients in setting both domestic and global benefit and compensation plan strategy, design, and implementation. In addition, we can analyze current COLI and split-dollar policies, identify areas of potential non-compliance, recommend viable solutions, and develop procedures for implementing those solutions.

Insurance products

Life insurance and annuity products are continually evolving as demographics and needs change. We help clients answer their tax-related questions about insurance products. Our professionals are experienced in COLI and split-dollar, exchanges of life insurance and annuity policies, and separate accounts.

Life insurer actuarial review

Our tax and actuarial professionals consult with life insurers on a variety of tax reserve issues, including the interpretation of tax reserve requirements, IRS audit support (including IRS software tools), and comprehensive reserve reviews.

Other insurance tax services

PwC provides various other tax-related services that help clients refine their tax structure, implement tax-planning strategies and address compliance issues, including legislative and regulatory policy, consolidations, reinsurance, broker/dealer, and insurance wholesalers. We also have broad experience with general federal tax compliance issues such as net operating losses, general business credit, depreciation, tax provision review, and alternative minimum tax.