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

Description: Complete issue of the February 2014 Taxing Times newsletter.

Description: This article addresses the scope of reserve valuation rules that compute or estimate reserves “on the basis of recognized mortality or morbidity tables, and assumed rates of interest.”

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: This article summarizes a recent revenue ruling concerning the insurance company qualification of an affiliate that reinsures retiree health benefits under an arrangement entered into by a VEBA.

Description: This is the September 2010 issue of the Taxation Section newsletter, Taxing Times.

Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

Description: Taxing Times - Supplement to the May 2012 issue

Description: September 2009 issue of the Taxation Section newsletter, Taxing Times.