Description: The article summarizes several recent private letter rulings from the IRS addressing the "investor control" doctrine in the context of funds of funds.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: Discusses PLR 201105012, the investor control doctrine, and how the IRS concluded that shares of a Lifecycle Fund, available only through a life insurance company's separate account, still can be considered owned by the insurer and not the policyowner for federal income tax purposes even if it at least partly invests in shares of public funds.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.

Description: Tidbits relate to contingent deferred annuities, wellness benefits in qualified long-term care contracts, and reactivating the active financing exception for insurance companies.