Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].

Description: Presented at October 1985 Annual Meeting. Discusses proposals for changing the tax law with respect to the taxation of personal income: The tax climate that led to these proposals, A description of the major proposals including the Treasury proposal pending in Congress, How these proposals will affect the design, marketing and sale of individual life and annuity products.

Description: Presented at October 1985 Annual Meeting. Discusses current topics involving insurance companies, such as: Impact on product design, Allocation of capital and resources, Consolidation, Regulations, Company structure, Proposed or current legislative matters.

Description: 1992 SOA Regional Meeting, Anaheim. This session addressed tax compliance, the tax consequences of life insurance contract failure, the correction of failed contracts, and a 1992 update on the proposed deferred acquisition cost tax regulations.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

Description: This 2008 supplement addresses the issues that have arisen in life insurance tax laws related to IRC 7702 and 7702A since the book was published in 2004. It also enhances and clarifies issues that were addressed in the text, adding detail and further discussion.

Description: This session discussion is about SPWL: Is a modified endowment product salable, 7 pay: What sales applications are working best and pricing and administrative compliance issues. From Record of the Society of Actuaries Vol. 15, No. 2A.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

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: 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.