Agenda
Day 2
CURRENT ISSUES IN LIFE INSURANCE AND ANNUITY/LTC TAXATION
The program on Tuesday and Wednesday will focus on current developments in the taxation of the life insurance and annuity/LTC products. It will provide an up-to-date perspective on a range of topics that are of interest to product designers and tax practitioners.
| 8:00 a.m. |
Registration and Continental Breakfast |
| 9:00 a.m. |
Introduction and Welcome
Chris DesRochers, SMART Business Advisory and Consulting, LLC and Kory Olsen, Taxation Section Chairperson |
| 9:15 a.m. |
SESSION I–Life Insurance Product Tax Update: 7702 and 7702A
- What is "cash surrender value?" What contractual promises may be treated as creating a "cash surrender value?" What issues arise from the existence of a non-traditional "cash surrender value?"
- If a contract has two alternative cash surrender values, what guarantees must be taken into account?
- The new mortality table for burial insurance
- Section 7702 grandfathers and Chief Counsel Advice memorandum 200805022 (Aug. 17, 2007)
- Simultaneous transaction processing issues
- 2001 CSO and extension of maturity dates
- Session Chair: John Adney, Davis & Harman LLP
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- Faculty: Barbara Gold, Prudential Insurance Company
- Doug Hertz, SMART Business Advisory and Consulting, LLC
- Don Walker, Farm Bureau Life of Michigan
- Sheryl Flum, Office of Associate Chief Counsel (Financial Institutions & Products)
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| 10:30 a.m. |
Break |
| 10:45 a.m. |
SESSION II–Life Insurance Product Tax Update: Other
- COLI/BOLI/IOLI
- Notice 2008-42 (modification of split dollar plan)
- LTC Combination Products
- Section 817(h) Diversification and Investor Control Issues
- The expense charge rule 20 years after enactment
- Session Chair: Chris DesRochers, SMART Business Advisory and
Consulting, LLC
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- Faculty: Craig Springfield, Davis & Harman LLP
- Ann Cammack, MassMutual Financial Group
- Susan Hotine, Scribner, Hall & Thompson LLP
- Mark Smith, Office of Tax Policy, Treasury
Department
- Linda Boyd, Office of Associate Chief Counsel (Financial Institutions & Products)
|
| 12:00 p.m. |
Keynote Luncheon
Convergence of Accounting Systems–Implications of IFRS and Principle-Based Methodologies.
- Introduction: Kory Olsen, Taxation Section Chairperson
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- Luncheon Speaker: Howard Stecker, SMART Business Advisory and Consulting, LLC
|
| 1:45 p.m. |
BREAKOUT SESSION I–(Choose one from Sessions A–C)
- A. Section 1035 Exchanges
- Session Chair: Mark Griffin, Davis & Harman LLP
- Faculty: Mark Rush, MassMutual Financial Group
- Don Drees, Office of Associate Chief Counsel (Financial Institutions & Products)
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- B. Longevity Products
- Session Chair: Chris DesRochers, SMART Business Advisory and Consulting, LLC
- Faculty: Laurie Lewis, Phoenix Companies Inc.
- Joe McKeever, Davis & Harman LLP
- John Glover, Office of Associate Chief Counsel (Financial Institutions & Products)
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- C. Tax and the Product Development Process
- Session Chair: John Adney, Davis & Harman LLP
- Faculty: Ann Delaney, John Hancock Life Insurance Company
- Kory Olsen, Pacific Life Insurance Company
|
| 2:30 p.m. |
Break
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| 2:45 p.m. |
BREAKOUT SESSION II–(Choose one from Sessions D-F)
- D. Defining "Insurance" from a Tax Perspective
- Session Chair: Rick Gelfond, Deloitte Tax LLP
- Faculty: Greg Stephenson, SMART Business Advisory
and Consulting, LLC
- Peter Winslow, Scribner, Hall & Thompson LLP
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- E. Tax Issues in Life Settlements
- Session Chair: Michael LeBoeuf, SMART Business Advisory and Consulting, LLC
- Faculty: Richard Safranek, Deloitte Tax LLP
- Kirk Van Brunt, Davis & Harman LLP
- Josephine Firehock, Office of Associate Chief Counsel (Financial Institutions & Products)
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- F. Product Issues in Qualified Plans
- Session Chair: W. Mark Smith, Sutherland, Asbill & Brennan LLP
- Faculty: Jason Bortz, Davis & Harman LLP
|
| 3:45 p.m. |
SESSION III–Annuity Product Tax Update
- Stand-alone guaranteed withdrawal benefits
- Additional benefits: Characterization, when charges give rise to distributions, effects under section 72(s), treatment as cash value
- Partial exchanges and partial annuitizations
- Annuity starting dates: Do you need one? If so, by what age and what must happen when it is reached?
- Session Chair: Joe McKeever, Davis & Harman LLP
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- Faculty: Richard Skillman, Caplin & Drysdale
- Laurie Lewis, Phoenix Companies Inc.
- Bryan Keene, Davis & Harman LLP
- Sheryl Flum, Office of Associate Chief Counsel (Financial Institutions & Products)
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| 5:30 p.m. |
Reception–Offices of Davis & Harman LLP |
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