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: Updated discussion of IRS Proposed Regulations under Section 162(m)(6), their potential impact upon the life insurance industry, and a 2 percent de minimis exception.

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.

Description: The author discusses some common myths about Congress’ tax policy under the 1984 Act that he would like “to debunk.”

Description: The Phase 3 tax is the description given to the federal income tax imputable to amounts withdrawn from the Policyholders Surplus Account maintained under the federal income tax law. This article discusses certain facets of the federal income Phase 3 tax as it relates to these withdrawals. Still significant for a large health insurer that has been in existence since before 1984 should health care become nationalized.

Description: IRS published final regulations on updated life expectancy and distribution period tables used for determining RMDs. The article intends to provide an overview on the development of the final regulations and highlight the key updates in final regulations, the transition rules to apply final regulations and some of the relevant issues not addressed in final regulations (e.g. MITT, Rev. Rul. 2002-62 and Notice 2004-15). The article also briefly discusses what financial institutions and actuaries would like to do before the regulations become effective on Jan. 1, 2022.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: Article from The Actuary September 1989 – Volume 23, No. 8 discusses TAMRA: the U.S. Technical and Miscellaneous Revenue Act of 1988.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

Description: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.