Description: The article summarizes PLRs 201515001 and 201519001, in which the IRS addressed the treatment of a non-qualified deferred annuity contract under the investor control doctrine and other applicable rules. The contract provides a guaranteed lifetime withdrawal benefit and investment options that correspond to “public” mutual funds. The IRS concluded that the investor control doctrine will apply to treat the contract purchaser as the owner of the mutual fund shares for federal income tax purposes. The IRS also addressed certain other tax aspects of the arrangement. The effect of the rulings is that the contract will be taxed similarly to a contingent deferred annuity (where the policyholder holds the mutual fund shares in his or her own brokerage account), while being structured like a traditional deferred variable annuity (where the insurance company holds the shares in its separate account).

Description: ERM and Investment strategies for healthcare companies

Description: How to set asset assumption, at the cycle or through the cycle and other considerations

Description: Article Nathaniel Ingersoll Bowditch by Bartlett in The Actuary, June 1979, Volume 13, Number 6

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: Discusses the importance of making tax-motivated investment decisions regarding one portfolio of a company within the context of the overall tax return of which the portfolio is a part, not necessarily on the tax effect of the portfolio alone.