Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.

Description: The article discusses the practical impact of recently Rev. Rul. 2014-7, which modified and supercedes Rev. Rul. 2007-54 by republishing the position of what variable annuity contract reserves are taken into for tax purposes without addressing the issue of how to calculate required interest for separate accounts; Rev. Rul. 2014-7 also obsoleted Rev. Rul. 2007-61, which had suspended Rev. Rul. 2007-54.

Description: A discussion of risk and tax risk.

Description: This article discusses new tax reporting requirements for transfers for value under section 6050Y. It also discusses changes to the transfer for value rule of section 101(a)(2) and (3), including the definition of a reportable policy sale.

Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: On June 26, 2013, the Supreme Court released its decision in the case of United States v. Windsor, Executor of the Estate of Spyer, et al. addressing the constitutionality of the federal Defense of Marriage Act (“DOMA”). This article explores the implications for life insurance and annuity contract spousal provisions that are governed by federal law.

Description: TAXING TIMES recently sat down with a group of retired tax actuaries to hear about how they got involved in actuarial tax matters and how their tax experience impacted their careers. Their insights will be useful for actuaries who are just starting out in the profession, as well as more seasoned actuaries.

Description: This article discusses the guidance provided in IRS Notice 2022-6 and prior guidance on whether distributions from an individual account under a qualified retirement plan satisfy the exception to the 10 percent additional tax in Internal Revenue Code section 72(t) for certain substantially equal periodic payments.

Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

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.