Description: The article summarizes the new net investment income tax proposed regulations recently published by the IRS as they relate to life insurance and annuity contracts.

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: Discusses Internal Revenue Service Ruling 2011-9. Since ruling now applies to all taxpayers, not just the taxpayer in a prior private letter ruling, taxpayers that have taken a contrary position in past tax years may need to amend prior tax returns.

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: The article reviews the creation and interpretation of federal tax law, with specific application to the life insurance industry

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: 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: 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 the role played by the "Blue Books" issued by the Congress's Joint Committee on Taxation and the authority accorded them by a recent U.S. Supreme Court decision.