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: Discussion of private letter tax rulings on the definition of Cash Surrender Value for purposes of interpreting the definition of life insurance for the policyholder's taxation of the contracts.

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: The panelists from this session at the June 2000 meeting of the Society of Actuaries in San Diego compare and contrast separate account products sold in the U.S. and Canada in both the qualified/registered retirement market and the nonqualified market.

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: Presented at the April 1986 Spring Meeting. This session discussion is about the current issues other than those relating to the Tax Equity and Fiscal Responsibility Act 'TEFRA' of 1982, the Deficit Reduction Act 'DEFRA' of 1984 and the Retirement Equity Act 'REA' of 1984.

Description: The United States district court for the Southern District of Ohio recently issued its opinion in American Financial Group and Consolidated Subsidiaries v. United States. The issue in the case as framed by the Internal Revenue Service IRS was whether Actuarial Guideline XXXIII AG 33 applies retroactively or prospectively to the calculation of reserves for deferred annuity contracts. This article is a discussion of this opinion.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

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: 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.