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Federal Income Taxation of Life Insurance Companies

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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 discussion of Pub. L. No. 115-97 (informally known as the Tax Cuts and Jobs Act of 2017) and provisions specifically targeted at life insurance companies, including, among other things:

•  Changes to the tax reserve calculations in IRC Section 807 that were made to accommodate principle-based reserves.
•  Changes to the proration rules that eliminate the complex calculations under prior-law IRC Section 812 for purposes of determining the company’s share and policyholders’ share.
•  Changes to the capitalization rules for policy acquisition expenses that increase the proxy capitalization percentage applied to net premiums and lengthen the amortization period.
•  The repeal of the small life insurance company deduction.
•  The repeal of the operations loss deduction in IRC Section 810 and its replacement with the net operating loss rules in IRC Section 172 applicable to other corporations.
•  The change to the provisions in IRC Section 807(f) regarding changes in basis of determining reserves, eliminating the 10-year spread and treating such changes as automatic consent changes under IRC Section 481.
•  Some of the more significant general changes to the Internal Revenue Code, including, among other things, repeal of the corporate alternative minimum tax; the base erosion anti-avoidance tax in new IRC Section 59A; the participation exemption system dividend deduction in new IRC Section 245A designed to move the U.S. more toward a territorial tax system; the transition tax under IRC Section 965 and related effects on the foreign tax credit.

This pub also includes legislative changes and IRS rulings, tax-planning suggestions and hypothetical examples.

First published in 1983.

3 Volumes; Loose-leaf; updated annually.

Table of Contents

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