Description: The article reviews the creation and interpretation of federal tax law, with specific application to the life insurance industry

Description: In this article, the authors take an exploration of the pertinent life insurance and political history along with a review of certain aspects of federal income tax policy.

Description: Basic discussion of premiums paid, investment in the contract, and basis as used in IRC provisions applicable to life insurance and annuity contracts.

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: Discusses Internal Revenue Service Ruling 2011-9. Since ruling now applies to all taxpayers, not just the taxpayer in a prior private letter ruling, taxpayers that have taken a contrary position in past tax years may need to amend prior tax returns.

Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

Description: The articles describes Revenue Procedure 2018-20, providing historical background as well as discussing the content of the new procedure.

Description: The article discusses a recent IRS private ruling on the application of the investor control doctrine to a variable contract for which the insurer proposed to add a new investment option. The new option closely paralleled a mutual fund that was open to public investment, i.e., it appeared to be a "clone," but the new option was itself not available outside of the variable contract. The IRS ruled that the doctrine did not apply.

Description: The article discusses the role played by the "Blue Books" issued by the Congress's Joint Committee on Taxation and the authority accorded them by a recent U.S. Supreme Court decision.

Description: Summary of private letter ruling the IRS released in February 2013 regarding a partnership formed to hold and manage bank-owned life insurance contracts. The article follows up another article from the same authors in the May 2012 issue of Taxing Times regarding an earlier ruling on a similar structure.