Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

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: 1994 SOA Meeting, San Antonio. This session provided an update from representatives of the IRS and the Department of the Treasury on several topics including: 1. PBGC issues. 2. Social Security issues. 3. Health care issues. 4. Title I issues. 5. Broad principles underlying some remedial amendment period issues.

Description: Presented at April 1985 April Meeting. This session discussed: Annuities, Non-participating life products, Participating life products, Variable products

Description: This article discusses the June 23, 1977 Supreme Court ruling that a life insurance company must include the net valuation portion but not the associated loading of deferred and uncollected premiums in its assets and gross premium income as well as in its reserves in computing its tax liability. Some companies have been using this procedure or a modification of it for the past few years. Other companies have been filing returns conforming to IRS regulations which required including gross deferred and uncollected premiums. These companies may need to file amended returns for open tax years if they paid taxes not due or understated usable operations/loss carry forwards. The author then goes on to review the implications of the court’s decision for companies filing amended returns.

Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: This letter discusses answers to the question “Is Homogeneity Required to Qualify as Insurance?”

Description: This article is a discussion of the proposal to tax the inside build-up in life insurance policies and the consequences if it were to be adopted.