Description: Company Tax Issues

Description: Update to initial article in Sept. 2007 issue, because of two new revenue rulings: Rev. Rul. 2007-54, 2007-38 I.R.B. 604 and Rev. Rul. 2007-61, 2007-42 I.R.B. 799.

Description: Discusses of the application of disproportionate asset acquisition rules under the life/nonlife regulations. How the amount of premiums or reserves should be measured is also discussed in detail.

Description: The article summarizes PLRs 201515001 and 201519001, in which the IRS addressed the treatment of a non-qualified deferred annuity contract under the investor control doctrine and other applicable rules. The contract provides a guaranteed lifetime withdrawal benefit and investment options that correspond to “public” mutual funds. The IRS concluded that the investor control doctrine will apply to treat the contract purchaser as the owner of the mutual fund shares for federal income tax purposes. The IRS also addressed certain other tax aspects of the arrangement. The effect of the rulings is that the contract will be taxed similarly to a contingent deferred annuity (where the policyholder holds the mutual fund shares in his or her own brokerage account), while being structured like a traditional deferred variable annuity (where the insurance company holds the shares in its separate account).

Description: Basic discussion of premiums paid, investment in the contract, and basis as used in IRC provisions applicable to life insurance and annuity contracts.

Description: Update from the ACLI about its continued contact with Treasury relating to AG VACARVM and Life PBR.

Description: Reserves for Annuity Contracts that Flunk Section 72(s) Can be Deductible

Description: A review of the different entities reading the newsletter, including actuaries, lawyers, accountants, tax professionals and government personnel.

Description: A summary discussion of those items listed in the 2012-2013 Priority Guidance Plan issued by the IRS and Treasury that address tax issues of concern to life insurance companies.

Description: This article begins with a brief review of the treatment of QAB charges under the Code and the guidance the Internal Revenue Service the “Service” has issued regarding the manner in which taxpayers should account for QAB charges Part I. It then describes Rev. Rul. 2005-6’s three alternatives for addressing improper accounting for QAB charges Part II. It also includes a discussion about an Alternative C closing agreement.