Description: Presented at October 1985 Annual Meeting. Discusses proposals for changing the tax law with respect to the taxation of personal income: The tax climate that led to these proposals, A description of the major proposals including the Treasury proposal pending in Congress, How these proposals will affect the design, marketing and sale of individual life and annuity products.

Description: This article addresses the 2001 CSO Mortality Table and the implications for preneed insurance, for which the table has been deemed inadequate. The article explores interim measures such as additional reserves, treatment as substandard, and tax implications. There is also discussion of a model NAIC regulation which would mandate the use of 1980 CSO mortality for preneed as well as efforts to eventually establish a new preneed mortality table for valuation and nonforfeiture purposes.

Description: This discussion looked at defining tax parity between mutual companies and stock companies as well as the consequences of failure to achieve tax parity.

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: This panel at the SOA 1982 Orlando Spring Meeting discusses tax parity for individual life insurance companies and products. The focus is on some of the very basic issues of taxation as the industry begins planning for a longer range solution to the issues posed by the current tax structure.

Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.

Description: This article comments on a 1972 paper on the same subject by John Fraser, which made a very careful analysis of the relation between the current earnings rate and the taxable interest. The author builds on Fraser’s illustrative calculations, which showed clearly that there was an optimal spread between the current earnings rate and the assumed reserve interest rate to produce the maximum interest deduction, by including an analysis of the after-tax yield effect.

Description: The Revenue Act of 1987 amended section 807d2B of the Internal Revenue Code. It established the interest rate used in the calculation of tax reserves to be the greater of the applicable federal interest rate or the prevailing maximum statutory valuation rate for the contract’s calendar year of issue. The amendment is effective for contracts issued in tax years beginning after December 31, 1987. This document shows all the applicable federal interest rates from 1998 - 2009.

Description: This is a discussion of the paper, Actuarial Note: Valuation of Reversionary Interests Involving Two or More Lives for Federal Tax Purposes by Charles G. Groeschell and William M. Snell. From Transactions of Society of Actuaries 1951, Vol. 3, No. 7.

Description: In September 2009, the Internal Revenue Service IRS released a private letter ruling PLR 200939018 June 18, 2009 addressing a contract in which the right to receive annuity payments and otherwise access a contract’s cash value is contingent upon the annuitant living to a specified age. The ruling holds that the contract is an annuity contract for purposes of section 72 of the Code. This article reviews the specifics of the ruling.