Description: The article summarizes several recent private letter rulings from the IRS addressing the "investor control" doctrine in the context of funds of funds.

Description: Provides information on Section 7702 mortality requirements, the implications of the adoption of the 2017 CSO tables and the need for IRS guidance.

Description: Primer on the federal income taxation of nonqualified annuities

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: The Society of Actuaries are once again offering a seminar that investigates all aspects of life insurance, annuity and long term care product tax compliance. Developed by the Taxation Section, participants will be brought up-to-date on recent Internal Revenue Service (IRS) guidance and learn about the newest tax issues related to product design and administration. Legal, IRS and product development experts will provide vital insights into the challenges of developing and administering products within the requirements of the Internal Revenue Code (IRC), and allow ample opportunities for networking, questions and information exchange.September 12The optional “boot camp” will provide an intense introduction to the basics of product taxation. The boot camp will include sessions focused on life insurance, annuities, and long-term care combination products. The basis of the boot camp will be the authoritative textbooks, “Life Insurance and Modified Endowments Under IRC Sections 7702 and 7702A” and the “Annuities Answer Book.” Book authors will conduct these optional programs. September 13–14The general sessions will feature product, tax, legal and compliance experts as well as Internal Revenue Service (IRS) representatives. Recent changes in the qualification requirements of insurance products and a host of product tax issues beyond Internal Revenue Code (IRC) section 7702 and 7702A will be emphasized.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: The article discusses a recent IRS private letter ruling granting IRC section 72(b) exclusion ratio treatment for amounts received from an innovative payout option.under a deferred variable annuity.

Description: A detailed discussion on Private Letter Ruling 20123009 which states that owners of life insurance contracts in some circumstances want to decrease their death benefits and that the decreases contemplated are not ones resulting from application of a formula or other provision set forth in the contracts.

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 discusses a recent IRS private ruling on the application of the investor control doctrine to a variable contract for which the insurer proposed to add a new investment option. The new option closely paralleled a mutual fund that was open to public investment, i.e., it appeared to be a "clone," but the new option was itself not available outside of the variable contract. The IRS ruled that the doctrine did not apply.