Book

Federal Income Taxation of Insurance Companies, Fourth Edition, with 2018 Supplement

 

Federal Income Taxation of Insurance Companies, Fourth Edition, provides a comprehensive analysis of life and nonlife insurance company taxation in the United States, including corporate tax issues, the taxation of captive insurance arrangements, and provisions related to special health insurance providers.        


Meet The Author

Description

Federal Income Taxation of Insurance Companies, Fourth Edition, provides a comprehensive analysis of life and nonlife insurance company taxation in the United States, including corporate tax issues, the taxation of captive insurance arrangements, and provisions related to special health insurance providers.

Highlights of the new Fourth Edition include:

  • Analysis of the shift from the use of formulaic reserve rules to the use of numerous factors, including stochastic factors, under the new Principle-Based Reserving (PBR) rules applied by life insurers to compute reserves for many contracts  
  • New alternative tax rules for qualified property and casualty insurers under section 831(b) that increase the limit on an insurer’s direct written premiums and impose diversification requirements that insurers must satisfy
  • Amended section 833(c)(5) and related Treasury Regulations that conform the Medical Loss Ratio (MLR) to the ratio that influences the rebate a Blue Cross/Blue Shield organization would have to pay if its MLR is too low under non-tax rules added by the Affordable Care Act
  • Court decisions that address important insurance company tax principles, including the continuing significance of the investor control doctrine, in Webber v. Commissioner, and the qualification of coverage as insurance by a captive, in Rent-A-Center v. Commissioner, when the captive’s liabilities were guaranteed for as much as millions of dollars
  • Other court decisions and IRS pronouncements that will enable tax specialists to address many difficult insurance company tax issues.

The Appendices to the edition also include tables of statutes, treasury regulations, cases, IRS pronouncements, and written determinations, as well as a full index.

 

Highlights of the 2018 Supplement include:

 

  • Insurance company tax changes enacted by the Tax Cuts and Jobs Act

  • New proration rules for property and casualty insurers, and the repeal of Section 847, regarding special estimated tax payments

  • Significantly simplified proration rules, the repeal of the small life insurance company deduction, and new tax reserve valuation rules for life insurers

  • Principle-based reserve rules used to determine statutory reserves, which became operative on January 1, 2017, simplifying the computation of life insurance company tax reserves

  • The Avrahami case, involving various coverages by a captive in a “microcaptive” arrangement where payments to the captive did not qualify as deductible premiums.

 

“This book is widely used throughout our National Insurance and Health Plan Practice. With the expansion of technical coverage and depth of content, it has utility and value at all levels of our organization, from a staff level up to partner.”

 

-- Christopher M. Puglia and Jeffrey J. Webb

 

    Deloitte Tax, LLP

 

“The author does an excellent job of breaking down the Code, Treasury Regulations, accounting principles and other authorities into easy-to-understand terms, making this book an essential resource for practitioners.”

 

                                                       --   David J. Slenn

 

                                                            Shumaker, Loop & Kendrick, LLP

 

                                                            Former Chair, Captive Insurance Committee, ABA Business Law Section

 

Summary of Contents

 

Chapter 1. Why Are There Separate Tax Rules for Insurance Companies?

 

Chapter 2. What Is Insurance?

 

Chapter 3. What Is an Insurance Company?

Chapter 4. Life Insurance Company Taxable Income

Chapter 5. Reinsurance Transactions and Deferred Acquisition Costs (DAC)

Chapter 6. Life Insurance Company Reserves

Chapter 7. Separate Accounts

Chapter 8. Policyholder Dividends

Chapter 9. Proration

Chapter 10. Property and Casualty Insurance Companies

Chapter 11. Special Health Insurance Providers

Chapter 12. Corporate Taxation of Insurance Companies

Appendices. Tables of Statutes, Treasury Regulations, Cases, IRS Pronouncements, and Written Determinations

 

Author

 

Emanuel S. Burstein holds a B.A. from Brandeis University, a J.D. from Boston College Law School, and an LL.M. in taxation from the New York University School of Law. He addressed insurance tax issues at the Office of Chief Counsel at the Internal Revenue Service and was the editor of The Insurance Tax Review.

Contents

Reviews

“This book is widely used throughout our National Insurance and Health Plan Practice. With the expansion of technical coverage and depth of content, it has utility and value at all levels of our organization, from a staff level up to partner.”

Christopher M. Puglia and Jeffrey J. Webb

Deloitte Tax, LLP

"The author does an excellent job of breaking down the Code, Treasury Regulations, accounting principles and other authorities into easy-to-understand terms, making this book an essential resource for practitioners."

David J. Slenn

Shumaker, Loop & Kendrick, LLP; former Chair, Captive Insurance Committee, ABA Business Law Section

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