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Insurance Tax Bulletin newsletter archive
This weekly publication provides one-page summaries of insurance tax developments affecting insurance companies and their products.
April 2013
- Court allocates basis to stock acquired from demutualization transactions upon sale of stock
- Budget proposal to disallow deduction for reinsurance premiums paid to affiliates; other insurance tax provisions
March 2013
- IRS determines that exchange of life insurance policies qualifies as tax-free
- Deficiency reserves included in statutory reserve cap that applies to life insurance reserves
February 2013
- Connecticut insurers to pay refunded assessments to Connecticut Department of Revenue Services
- Court rules in favor of IRS in demutualization case
- IRS grants foreign insurance company an extension of time to file certain elections
- IRS issues Final FATCA regulations
- Prevailing interest rates for computing certain insurance reserves
- Federal excise tax: Insurance 'Cascading' FET - Protective refund claims
November 2012
October 2012
September 2012
August 2012
- Oregon Tax Court decisions suggest disparate treatment of in-state and out-of-state insurance companies
- Certified HMO is included in a unitary group's Massachusetts combined excise tax return
- PA Court ruled insurance companies may take a premium tax credit for assessments measured by their annuity receipts
- IRS deems change to insurance contract a 'new' contract
- Roadside assistance provider can be taxed as an insurance company
- Open transaction doctrine does not apply where stock basis can be reasonably allocated
July 2012
- Foreign company qualifies as domestic insurance company and reinsurance premiums are deductible business expense
- IRS denies Taxpayer's request to revoke small insurance company election
June 2012
- Insurance revenue proposals in President Obama's FY 2013 Budget
- IRS denies exempt status to insurance trust
- Continuing Developments in the Taxation of Insurance Companies
May 2012
- ITB 12-21: You’re invited: A Professional education program hosted by PwC Chicago
- ITB 12-20: COLI policies purchased by a closely held corporation satisfies section 101(j)(4)
April 2012
- ITB 12-19: SSAP 101 Webcast - May 8, 2012
- ITB 12-18: SSAP 101 Q1 "To Do" List
- ITB 12-17: West Virginia enacts captive insurance legislation
- ITB 12-16: IRS seeks comments on collection requirements related to the the application of section 338 to insurance businesses
- ITB 12-15: Stock life insurance company's long-term care rider will be treated as insurance contract
March 2012
- ITB 12-14: IRS ruled that insurance sub is eligible to be part of the parent's consolidated group
- ITB 12-13: PwC insurance industry thought leadership: Top issues and strategic risk management
February 2012
- ITB 12-11: Q&A released for SSAP No. 101, Income Taxes, A replacement of SSAP No. 10R and SSAP No. 10
- ITB 12-12: S. 2048 - New reporting requirements for life insurance settlement transactions
- ITB 12-10: You're invited. A Professional education program hosted by PwC Chicago
- ITB 12-09: Dutch tax court rules in favor of Dutch tax administration in captive insurance company case
- ITB 12-08: You are invited: The Foreign Tax Compliance Act (FATCA) Webcast
- ITB 12-07: IRS issues temporary regulations for recognition as a qualified nonprofit health insurance issuer
- ITB 12-06 - Policyholder dividends deductible in the year declared
- ITB 12-05: Massachusetts proposed budget includes tax on pass-through entities' non-insurance income
January 2012
- ITB 12-03: IRS updates 2011-2012 priority guidance plan
- ITB 12-04: Fifth circuit finds insurance deposits by business not deductible as premiums
- ITB 12-02 Prevailing interest rates for computing insurance reserves
- ITB 12-01: Upcoming SALT Webcast: Stay informed: Indirect tax issues affecting the financial services industry
- ITB 11-75: IRS rules on tax implications of transfer of BOLI policies and deductibility of unrelated interest expenses
- ITB 11-74: Reserve amount calculation for foreign report purposes is an acceptable method to measure insurers' foreign personal holding company income
- ITB 11-73: PwC Guide to Accounting for Income Taxes—2011 edition
December 2011
- ITB 11-72: A contract protecting against market decline is not insurance
- ITB 11-71: Supplemental unemployment insurance payments subject to reporting
- ITB 11-70: Draft Q&A for SSAP No. 101, Income Taxes, A Replacement of SSAP No. 10R and SSAP No. 10
- ITB 11-69: S. 1880 would repeal Health Insurance Tax in PPACA
November 2011
- ITB 11-68: You are invited: Current Trends in Insurance M&A webcast - December 6, 2011
- ITB 11-67: PwC's Ken Kuykendall part of BNA webcast, IFRS Convergence: What U.S. Tax Executives Need to Know NOW
- ITB 11-66: Current year deduction for bonuses paid in following year
- ITB 11-65: SSAP 101 unanimously adopted by NAIC
- ITB 11-64: International comparison of insurance taxation, 2011
October 2011
- ITB 11-63: Sections 832 and 846 discount factors for 2011
- ITB 11-62: Russian Tax Service adopts VAT rules for insurance, reinsurance
- ITB 11-61: Revised Neal Bill introduced: Disallowance of deduction for non-taxed reinsurance premiums paid to affiliates
- ITB 11-59: Ukraine provides guidance on profit tax liabilities for cross-border reinsurance contracts
- ITB 11-58: You're invited: State and local tax trends and issues affecting insurance companies
- ITB 11-60: Prevailing interest rates for computing insurance reserves
September 2011
- ITB 11-56: IRS announces non-application of Section 6050W to insurance companies that administer certain insurance arrangements
- ITB 11-54: Illinois law makes important changes for income tax treatment of insurance companies
- ITB 11-55: Professional Development Program for the financial services industry
- ITB 11-53: Reasonable expense charges may be deducted in computing deemed cash surrender value
- ITB 11-52: IRS will not refund tax paid on sale of stock received in demutualization
- ITB 11-51: NAIC's Financial Condition Committee approves SSAP 101
- ITB 11-50: President Obama proposes $1.5 trillion in new taxes as part of deficit reduction plan; calls for comprehensive tax reform
- ITB 11-48: IRS provides guidance on schedule UTP
- ITB 11-49: IRS seeks comments on qualified insurance income guidance for CFCs
- ITB 11-46: Insurer's exemption revoked for exceeding gross receipts limitation
- ITB 11-47: IRS reissues interim guidance on case referrals for foreign insurance excise tax
- ITB 11-44: IRS addresses interaction of dual consolidated losses and SRLY rules
- ITB 11-45: IRS provides section 842(b) percentages for foreign insurers for 2010
- ITB 11-43: IRS publishes 2011-2012 priority guidance plan
August 2011
- ITB 11-42: No intercompany elimination for dividends paid by insurance subsidiary, Oregon Tax Court holds
- ITB 11-41: IRS issues proposed regulations relating to health care premium tax credit
- ITB 11-40: Annuity and life insurance contracts with a long-term care insurance feature
- ITB 11-39: IRS LB&I directive on codified economic substance and related penalties
- ITB 11-37: Nevada premium tax audit activity
- ITB 11-38: Illinois income tax treatment for holding companies
- ITB 11-36: Final OID regulations rendered prior guidance obsolete
- ITB 11-34 Statutory Accounting Principles Working Group releases SSAP 101 Exposure Draft
- ITB 11-35: New PwC publication for the insurance industry on FATCA
July 2011
- ITB 11-33: IRS rules that investment contracts will be treated as annuities
- ITB 11-32: Annuities: Treatment of the Partial Exchange of an Annuity Contract
June 2011
- ITB 11-31: Proposed Increase in Alternative Tax Limitation for P&C Companies
- ITB 11-30: Extension of Interim Guidance on Modification of Section 833 for Blue Cross Blue Shield and Other Organizations
- ITB 11-29: General explanations of the Obama Administration's FY 2012 tax proposals
- ITB 11-28: IRS Seeking Public Comments on Tax Form, Regulations, and Notice
- ITB 11-27 Section 501-Exemption from Tax on Corporations
May 2011
- ITB 11-26 Certain Income of States excludable under Section 115
- ITB 11-25: U.S. District Court dismisses New York Life's policyholder dividend deduction claim
- ITB 11-24: HMO taxed as an insurance company despite capitated fees to physician networks
- ITB 11-23: Comments on SSAP No. 101-Income Taxes have been released
April 2011
- ITB 11-21: Annual Filing Requirements for qualified nonprofit health insurance issuers
- ITB 11-20: Insurance premiums deductible as ordinary expenses under Section 162
- ITB 11-22: Insurance holding company reorganization tax-free under Section 368
- ITB 11-19: You're invited. A Professional education program hosted by PwC Chicago
- ITB 11-18: Join PwC's Webcast: Transfer Pricing and Profit Allocation in the Insurance World
- ITB 11-17: Stock life insurance company's long-term care rider will be treated as insurance contract
- ITB 11-16: IRS ruled that a certificate issued by a life insurance company will be considered an annuity contract
- ITB 11-15: Join PwC's Webcast: Understanding the new FATCA Guidance - April 14, 2011
March 2011
- ITB 11-14: MTC Advances Proposal to Impose Tax on Majority-owned Pass-through Entities and LLCs Despite Insurance Industry Concerns
- ITB 11-13: NAIC Releases an Exposure Draft of Final Guidance on Income Tax Accounting under SSAP 10R.
- ITB 11-12 IRS Issues Guidance on Tax-Free Exchanges of Life Insurance Contracts
- ITB 11-11: Insurance Company will be treated as Owner of Underlying Investments
- ITB 11-10: IRS Denies Tax-Exempt Status to Auto Damage and Liability Insurer
- ITB 11-09: New thought leadership from PwC - Continuing Developments in the Taxation of Insurance Companies
- ITB 11-08: You’re invited. A Professional education program hosted by PwC Chicago
February 2011
- ITB 11-07: Insurance Tax CPE Courses
- ITB 11-07: Disallowance of the Deduction for Non-Taxed Reinsurance Premiums Paid to Affiliates
- ITB 11-05: Webcast on the Foreign Account Tax Compliance Act (FATCA)
- ITB 11-03: Insurance company is required to file Form 8300 for related transactions
- ITB 11-04: New COLI legislation recently introduced
