Description: This article begins with a brief review of the general requirements of section 7702A and the consequences of MEC status for a life insurance contract and continues with a description of the evolution of the inadvertent MEC correction procedures over the past near decade.

Description: A discussion of the PLR that addresses a Wellness Rider that an affiliated group of life insurance companies proposed to offer only on a prospective basis with newly issued life insurance contracts.

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: This article is a general discussion about prior correction procedures for failed life insurance contracts and the new IRS procedure for remediation.

Description: This article begins with a brief review of the treatment of QAB charges under the Code and the guidance the Internal Revenue Service the “Service” has issued regarding the manner in which taxpayers should account for QAB charges Part I. It then describes Rev. Rul. 2005-6’s three alternatives for addressing improper accounting for QAB charges Part II. It also includes a discussion about an Alternative C closing agreement.