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: The proposed regulations define a class of products known as “qualifying longevity annuity contracts” (QLACs), which are excluded from the account balance used to determine required minimum distributions. By exempting longevity annuities (up to a specified limit) from the RMD rules, it is hoped that it will provide individuals under defined-contribution plans the option to use an “affordable” portion of their account balance to purchase a longevity annuity. The proposed regulations apply to tax-qualified defined-contribution plans under section 401(a), section 403(b), individual retirement annuities and accounts (IRAs) under section 408, and eligible governmental section 457 plans.

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

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: A discussion of tail-design LTC riders for annuities and how contract cash values are offset by reductions to the annuity contract. LTC benefits, and how they relate to the annuity contracts, are also discussed.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without any published guidance on when annuity payments can be used to satisfy the SEPP [Substantially Equal Periodic Payments] exceptions to the 10 percent penalty tax under sections 72q2D and 72t2Aiv. This article discusses that problem. The insurance industry requested guidance on this issue.8

Description: Clarification of the tax treatment of non-qualified deferred annuities that are “partially annuitized” is discussed in detail in this article.

Description: Updates on partial annuitization and exhanges, prevailing CSO valuation mortality tables, disclosure of offshore accounts through FATCA.

Description: A discussion of substantially equal periodic payments, SEPPs, and the penalty tax that is associated with SEPPs, the Recapture Rule. Computation methods are also discussed.