Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: The Society of Actuaries are once again offering a seminar that investigates all aspects of life insurance, annuity and long term care product tax compliance. Developed by the Taxation Section, participants will be brought up-to-date on recent Internal Revenue Service (IRS) guidance and learn about the newest tax issues related to product design and administration. Legal, IRS and product development experts will provide vital insights into the challenges of developing and administering products within the requirements of the Internal Revenue Code (IRC), and allow ample opportunities for networking, questions and information exchange.September 12The optional “boot camp” will provide an intense introduction to the basics of product taxation. The boot camp will include sessions focused on life insurance, annuities, and long-term care combination products. The basis of the boot camp will be the authoritative textbooks, “Life Insurance and Modified Endowments Under IRC Sections 7702 and 7702A” and the “Annuities Answer Book.” Book authors will conduct these optional programs. September 13–14The general sessions will feature product, tax, legal and compliance experts as well as Internal Revenue Service (IRS) representatives. Recent changes in the qualification requirements of insurance products and a host of product tax issues beyond Internal Revenue Code (IRC) section 7702 and 7702A will be emphasized.

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: 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: 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: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

Description: This article begins with a brief review of the treatment of QAB charges under the Code and the guidance the Internal Revenue Service the “Service” has issued regarding the manner in which taxpayers should account for QAB charges Part I. It then describes Rev. Rul. 2005-6’s three alternatives for addressing improper accounting for QAB charges Part II. It also includes a discussion about an Alternative C closing agreement.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: The article discusses the impact of changes made to Internal Revenue Code Section 7702 by the ConsolidatedAppropriations Act, 2021. The Consolidated Appropriations Act made changes to the interest rates used calculatethe Section 7702 premium and cash value funding limitations for life insurance contracts