Description: A discussion of: the value of a life insurance contract distributed from a qualified pension plan, IRS industry director directive on the DRD for life insurance separate accounts and IRS actuaries raising new issues on AG 34 tax reserves.

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: On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine in Webber v. Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets supporting a variable life insurance contract purchased through a private placement transaction. In the end, however, the Webber court leaves a lot of questions unanswered—most significantly, the elusive answer to how to define investor control. This article examines the Investor Control Doctrine, as explained and applied by the U.S. Tax Court in Webber, and considers some of the open questions that remain after June 30, 2015.

Description: Recap of two summer 1967 tax court decisions stemming from the 1959 Life Insurance Company Income Tax Act

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

Description: Presented at April 1986 Spring Meeting. Addresses whether the newly imposed defined benefit pension guidelines are actuarially sound, is the IRS properly equipped to administer the guidelines, what are the professional implications of not complying with the guidelines and how have differences been resolved.

Description: Panelists discuss and debate existing tax laws and expected changes to tax laws relating to: taxation of mutual and stock life companies [Sec. 809], taxation of 'investment-oriented' products [Sec. 7702], and the federal government's continued need for 'revenue enhancement.' From the 1988 Record of Society of Actuaries, Vol. 14, No. 3.

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: 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: Un-MECing a MEC by Arthur C. Schneider & Cherri R. Divin from The Financial Reporter, October 1999, Issue No. 40.