Description: In session 75 PD of the New York Annual Meeting panelists explore practical considerations of maintaining compliance with federal income tax definition of life insurance rules. From the Record of the Society of Actuaries, Vol. 24, No. 3.

Description: This presentation is a concurrent session from the 1991 Meeting of the Society of Actuaries, held April 18-19 in New Orleans. In this life insurance product tax session, attorneys representing the American Council of Life Insurance ACLI, the Internal revenue Service, ‘IRS,’ and the law firm of Davis & Harman discuss the status of recent IRS Private Letter Rulings, current activities of the American Council of Life Insurance, ‘ACLI,’ and other topics including the international reach of Internal Revenue Code sections 7702 and 7702A. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 1.

Description: This session discussion is about SPWL: Is a modified endowment product salable, 7 pay: What sales applications are working best and pricing and administrative compliance issues. From Record of the Society of Actuaries Vol. 15, No. 2A.

Description: Overview of latest developments on IRC Section 7702, IRC Section 848, market value adjusted contracts, companies in rehabilitation and Canadian issues including: • Part I income tax • Part IV capital tax

Description: This presentation is a panel discussion, session 46PD, from the 2004 Spring Meeting of the Society of Actuaries, held June 14-15 in San Antonio, TX. The panelists, industry and tax leaders, discuss recent, ongoing and potential issues, including initiatives affecting various products and markets, including corporate-owned life insurance [COLI] and business-owned life insurance [BOLI] issues, as well as some of the recent guidance that's been issued that affects Section 412[i] plans. Other topics are Internal Revenue Code Sections 7702 and 7702A, and the 2001 CSO Mortality Table. Discussion from participants is included. From the Record of Society of Actuaries, Volume 30, No. 2.

Description: Guidance and interpretation regarding reasonable mortality charge requirement of Section 7702, based from IRS Notice 2004-61, 2004-41 I.R.B. 596 of October 12, 2004.

Description: This 2008 supplement addresses the issues that have arisen in life insurance tax laws related to IRC 7702 and 7702A since the book was published in 2004. It also enhances and clarifies issues that were addressed in the text, adding detail and further discussion.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

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.