Description: Overview of latest developments on IRC Section 7702, IRC Section 848, market value adjusted contracts, companies in rehabilitation and Canadian issues including: • Part I income tax • Part IV capital tax

Description: After outlining some of the issues involved in the taxation of life insurance companies, this paper describes the tax consequences of various strategic courses of action by life insurance companies. From Transactions of Society of Actuaries 1981, Vol. 33.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: From a session at a meeting of the Society of Actuaries held in San Diego, CA, June 22-23, 2000 This discussion reviews the need for and a process for remediation of errors made with respect to an inadvertent non-egregious failure to comply with the modified endowment contract rules under Internal Revenue Code Section 7702A.

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: This session discussion is about Federal Income Tax, policy issues, single premium products, inside buildup and corporate owned life insurance. From Record of the Society of Actuaries Vol. 15, No. 2.

Description: From the 1960 Transactions Vol. 12 No. 32, this ‘Discussion of Subjects of Special Interest’ addresses the Life Insurance Company Income Tax Act of 1959.

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.