Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: Discusses taxation of derivatives, as changed for some types under Dodd-Frank and not changed for others.

Description: Tells what occurred after the adverse private letter ruling PLR 200738016 up to the issuance of the revenue procedure, and offers some speculation about the future.

Description: In February 2015, the Internal Revenue Service Chief Counsel appointed Alexis MacIvor as the chief of Branch 4 of the Office of the Associate Chief Counsel (Financial Institutions & Products). That branch (sometimes referred to by our readers as the “Insurance Branch”) has seven attorneys who work exclusively on issues concerning the taxation of insurance companies and the products those companies issue. Because of the importance of that branch’s work product to the issues that life actuaries must address every day, the Taxing Times Editorial Board and the Taxation Section Council thought our readers would appreciate the opportunity to meet Alexis and welcome her to the insurance tax actuarial community. Mark Smith of our editorial board recently met with Ms. MacIvor to talk about her background and her new role.

Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: The American Council of Life Insurers provides an update on recent tax-related ACLI activity. Topics in this issue include (1) the NAIC's Principle-Based Reserves (PBR) Review Working Group and its exposed revisions to the Annual Statement Blanks; (2) ongoing communications with the Internal Revenue Service and Treasury to seek published guidance on PBR; (3) an update on tax reform activity in Congress; (4) the framework for change issued by the NAIC's Variable Annuities Issues (E) Working Group; and (5) the ERISA Advisory Council's development of model notices and disclosures for pension risk transfers.

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.

Description: This article discusses the temporary waiver and how it provides only limited relief from the section 401a9 minimum distribution requirements.

Description: A discussion of, first, the three-year transition period for adopting principle-based reserves and how it might not apply to tax reserves, and second, the tax impact of adding investment options to in-force contracts.

Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.