LRA Updates

TAX DEVELOPMENTS IRS Priority Guidance Plan – Initial Implementation of Tax Cuts and Jobs Act On February 7, the IRS released an updated 2017-2018 Priority Guidance Plan. The plan reflects projects that the IRS hopes to complete during the twelve-month period from July 1, 2017 through June 30, 2018. The updated plan includes an initial…

TAX DEVELOPMENTS Interagency Statement on Accounting and Reporting Implications of the New Tax Law On January 18, the banking regulators released an interagency statement on the accounting and reporting implications of the newly enacted tax law (the “Act”). The statement briefly described the Act’s impact on Deferred Tax Assets (DTAs) and Deferred Tax Liabilities (DTLs), noting…

TAX DEVELOPMENTS Implications of Tax Cuts and Jobs Act (TCJA) for BOLI/COLI On December 22, President Trump signed into law the “Tax Cuts and Jobs Act” (TCJA). The implications of the TCJA are, of course, wide reaching for businesses. In this LRA update, we highlight several potential implications for BOLI/COLI. We will be publishing more…

TAX DEVELOPMENTS Senate Expected to Pass Tax Reform Bill As has been widely reported, the Senate GOP leadership has announced that they have secured the votes necessary to pass its version of the Tax Cuts and Jobs Act (S.1). It has been reported that several amendments have been agreed to in order to secure the…

TAX DEVELOPMENTS House Tax Reform Legislation Status Kevin Brady, the Chairman of the House Ways and Means Committee, announced yesterday that the planned release of tax reform bill text would be delayed one day to Thursday, November 2. He also stated, “We are pleased with the progress we are making and we remain on schedule…

TAX DEVELOPMENTS IRS Private Letter Ruling on Policyholder Implications of Assumption Reinsurance Transaction On September 8, the IRS publicly released a Private Letter Ruling (Number 201736019) regarding the federal income tax implications of an assumption reinsurance transaction on a group flexible premium variable life insurance policy. As set forth in the PLR, a Policyholder requested…

REGULATORY DEVELOPMENTS OCC Seeks Public Input on Volcker Rule On August 2, the OCC released a request for public comment on whether certain aspects of the Volcker Rule’s implementing regulation should be revised to better accomplish the purposes of section 619 of the Dodd-Frank Act and decrease the compliance burden on banking entities. Among the…

JUDICIAL DEVELOPMENTS FNB PA v. Transamerica – Summary Judgement Ruling On July 6, the District Court (PA-W.D.) issued its memorandum opinion with respect to Transamerica’s motion for summary judgment. The court entered judgment in favor of Transamerica. This dispute centered on whether FNB was paid the entire amount it was owed after it surrendered certain…

REGULATORY DEVELOPMENTS Treasury Report on Financial Regulation On June 12, the Treasury Department released a report, A Financial System That Creates Economic Opportunities, in response to President Trump’s executive order defining financial regulatory “Core Principles.” The Treasury report provides numerous recommendations for changes to the U.S. financial regulatory system and identifies Treasury’s view as to…

TAX DEVELOPMENTS Trump Fiscal Year 2018 Budget Proposal Last week, the Trump administration released its first Fiscal Year 2018 budget proposal, titled A New Foundation for American Greatness. Two priorities addressed in the 2018 budget that our readers may be most interested in are tax reform and financial regulatory reform. Tax Reform The Trump budget…