Description: The presenters will discuss recent developments related to the federal qualification and taxation of life insurance and annuity contracts. Among other topics, there will be a focus on comparing and contrasting life insurance product qualification in the U.S. under IRC sections 7702 and 7702A versus qualification in Canada under the 'exempt test' of the Income Tax Act, which has been revised in recent years. Discussion will include comparisons of Canadian provisions to U.S. definition of life insurance and Modified Endowment Contract concepts.

Description: Taxing Times, September 2006, Volume 2, Issue No. 2.

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

Description: Discusses how companies must ensure that significant and necessary product development, and administrative and compliance system changes, have been completed and tested in time to accommodate new requirements.

Description: Full version of Taxing Times, September 2005, Volume 1, Issue No. 2.

Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.

Description: Discusses the Age 100 safe harbor methodologies in the 2010 IRS revenue procedure, and then provided some considerations that insurers should keep in mind in applying these methodologies.

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: A discussion of the proposed safe harbor with respect to calculations for contracts where the insured reaches age 100.