Comment from American Council of Life Insurers
American Council of Life InsurersOpposeAdvocacy
Summary: The American Council of Life Insurers (ACLI) opposes proposed regulations regarding Adjusted Financial Statement Income (AFSI) adjustments, specifically arguing that the requirement to carve out amounts attributable to pre-2020 taxable years is practically impossible and creates undue administrative burdens. They recommend aligning the final regulations with the previous Notice 2023-64 approach, which takes into account the full amount of cumulative adjustments from accounting principle changes.
ACLI's comments on Prop. Reg. §1.56A-17 (Adjusted Financial Statement Income (“AFSI”) Adjustments to prevent certain duplications or omissions).