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INTERNATIONAL TAX DIALOGUE GLOBAL CONFERENCE October 26, 2009

INTERNATIONAL TAX DIALOGUE GLOBAL CONFERENCE October 26, 2009. Session 6 – Taxation of Insurance Richard Glaser - Partner Re. Discussion Topics. Taxation of Life Insurance Products Companies Taxation of Property/Casualty Insurance Products Companies

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INTERNATIONAL TAX DIALOGUE GLOBAL CONFERENCE October 26, 2009

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  1. INTERNATIONAL TAX DIALOGUE GLOBAL CONFERENCEOctober 26, 2009 Session 6 – Taxation of Insurance Richard Glaser - Partner Re

  2. DiscussionTopics Taxation of Life Insurance • Products • Companies Taxation of Property/Casualty Insurance • Products • Companies Taxation of Professional Reinsurers • Products • Companies Merger of Insurance and Capital Markets Definition of Insurance VAT and Insurance/Reinsurance

  3. Taxation of Life Insurance Products Issues • How is life insurance viewed as a social policy matter? • Should investment income be allowed to grow tax free (or deferred) to support the broader social policy goals? Companies Issues • Should life insurers be allowed “reserve accounting” for tax purposes? • Should insurance regulatory accounting methodologies be used as the basis for taxable income?

  4. Taxation of Property/Casualty Insurance Products Issues • What role does commercial insurance play in allowing commercial transactions to be consummated on reasonable terms? Companies Issues • If “reserve accounting” is acceptable for tax purposes, is reserve discounting appropriate?

  5. Taxation of Professional Reinsurers Products Issues • Related party reinsurance • Third party reinsurance Companies Issues The flagship business model concentrates capital in one jurisdiction which allows for distribution in multiple jurisdictions: • Rating agencies preferred business model • Regulator preferred business model • Tax administrators?

  6. Merger of Insurance and Capital Markets • Financial Guarantee Insurance versus Credit Default Swaps • Weather Insurance versus Weather Derivatives • Catastrophe Insurance versus “CAT Bonds”

  7. Definition of “Insurance” Products Issues - Is “insurance risk” present? • Finite Insurance/Reinsurance Companies Issues - Is risk transferred? • Captive Insurers/Reinsurers • Protected cell companies

  8. VAT and Insurance/Reinsurance • Interplay with other financial services • Recent ECJ AG opinion regarding loss portfolios

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