This session will focus on federal income tax issues of significance to P&C insurers, with particular emphasis on the deduction for losses and loss adjustment expenses. Also discussed during the session is the role of actuaries in explaining and defending the booked reserves before the IRS and in court, the definitions of "insurance" and "insurance company" for tax purposes. Finally, panelists will focus on recent IRS rulings regarding the excise tax on premiums covering U.S. risks reinsured and retro ceded offshore (including under treaties between non-U.S. companies), and legislative proposals disallowing ceded premium deductions.