Tax Challenges under Life PBR

Ann Cammack, FSA
Xuan Deng, ASA

As Life PBR became operative, insurance companies face new challenges when implementing and operating under the new regulation. What’s more, Life PBR does not easily fit into the existing structure of life insurance reserves (under IRC §807) developed by Congress in 1984. This session will start with a high-level overview of NAIC’s valuation manual, and pinpoint areas that may pose tax interpretational challenges. Then, the session will discuss the past IRS guidance and potential ways to approach major tax compliance issues. The session will conclude on a few practical considerations for companies to develop their tax positions.

Ann Cammack is a Principal with Ernst & Young’s National Tax Practice in Washington DC, where she focuses on the taxation of insurance companies and insurance products. Ms. Cammack has over 20 years of experience working on insurance company and product taxation. At EY, she represents clients before the Internal Revenue Service, Treasury Department and the US Congress, and assist clients with developing strategic solutions to taxation matters.

Prior to joining EY, Ms. Cammack was a Senior Tax Counsel with the Senate Finance Committee, working for Chairman Baucus and more recently Chairman Wyden. During her time with the Finance Committee, she was involved in the development of tax legislation affecting the insurance industry, as well as advising for general corporate and international tax matters. In Ms. Cammack had served as the attorney-advisor responsible for insurance company and product taxation at the US Treasury Department’s Office of Tax Policy, and acted as an attorney- advisor in the IRS Chief Counsel branch responsible for insurance company and product tax matters. Furthermore, Ms. Cammack had held executive positions at MassMutual and the American Council of Life Insurers and was a partner with the law firm of Sutherland, Asbill & Brennan. Ms. Cammack is a Fellow of Society of Actuaries (FSA).

Xuan Deng is a senior actuarial consultant in the Insurance and Actuarial Advisory Services practice of Ernst & Young LLP’s Financial Services Office. She is based in Chicago. She has over five years of experience in the life insurance industry, focusing on policyholder taxation compliance, corporate income tax provision audits, financial reporting, financial modeling, and actuarial transformation. Xuan is a graduate of University of Illinois and is an Associate of the Society of Actuaries (ASA).

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