The official NAIC stance seems to be that Actuarial Guidelines are not law, but just a "clarification" of the law (i.e., retroactive to the last revision of the SVL). I know FL adopts AGs as regulations, making them law. (There may be other states that do this.)
AG38 and AG48 are written like laws, including effective dates (which imply that the law changed based upon policy issue date). Many state regulators treat them as if they imposed minimum requirements (including the VM-20 requirements, despite the Valuation Manual not yet being effective). Does that make AG38 reserves tax-deductible?
AG38 and AG48 are written like laws, including effective dates (which imply that the law changed based upon policy issue date). Many state regulators treat them as if they imposed minimum requirements (including the VM-20 requirements, despite the Valuation Manual not yet being effective). Does that make AG38 reserves tax-deductible?
AG38 vs Tax Reserve