BOOK

Federal Income Taxation of Insurance Companies, Fourth Edition

 

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.        

Price: $249.00 Main Volume

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.


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