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: The PPACA imposed a market share-based health insurance provider fee, known as the "Section 9010 Fee", "Health Insurer Fee", or simply the "HIF", on each “covered entity” with net premiums written in excess of $25 million that is engaged in the business of providing health insurance coverage for U.S. health risks. This article provides background information to help unpack the language behind the Section 9010 Fee and highlights a few areas of special interest including merger and acquisition-related issues, application of the Section 9010 fee to expatriate plans, and considerations regarding fee administration.

Description: Examines Notice 2016-39 on phased retirement payments from defined benefit plans and its inapplicability to non-qualified annuities under Rev. Proc. 2016-36

Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

Description: The Tidbit summarizes LTRs 201609008 and 201613016 and discusses the definition of insurance under the tax code in light of these new pieces of guidance from the IRS.