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

Description: This article addresses the 2001 CSO Mortality Table and the implications for preneed insurance, for which the table has been deemed inadequate. The article explores interim measures such as additional reserves, treatment as substandard, and tax implications. There is also discussion of a model NAIC regulation which would mandate the use of 1980 CSO mortality for preneed as well as efforts to eventually establish a new preneed mortality table for valuation and nonforfeiture purposes.

Description: Discusses why it is so important for actuaries to actively monitor evolving issues with taxation of life insurance companies and products, and how to monitor the issues and get involved with the process.

Description: Article from The Actuary September 1989 – Volume 23, No. 8 discusses TAMRA: the U.S. Technical and Miscellaneous Revenue Act of 1988.

Description: A discussion of the three private letter rulings addressing the tax treatment of group insurance contingent annuity contracts providing guaranteed minimum withdrawal benefits linked to an investment account released by the Internal Revenue Service.

Description: The U.S. Technical and Miscellaneous Revenue Act of 1988 has created a very significant administrative problem for companies having a large block of “grandfathered” universal life business. The problem is that seemingly harmless future changes in benefits are categorized as “material changes,” causing a policy to lose its grandfather status and subjecting it to the “modified endowment” rules.

Description: On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine in Webber v. Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets supporting a variable life insurance contract purchased through a private placement transaction. In the end, however, the Webber court leaves a lot of questions unanswered—most significantly, the elusive answer to how to define investor control. This article examines the Investor Control Doctrine, as explained and applied by the U.S. Tax Court in Webber, and considers some of the open questions that remain after June 30, 2015.

Description: U.S. corporate federal income taxation of life insurance companies underwent a major revision several years ago with the adoption of the 1984 Tax Act, following two years of stopgap taxation under TEFRA '1982 Tax Act'. This paper highlights the SOA study notes, a text of the IASA and other documents that provide a comprehensive introduction to life insurance company taxation.

Description: The article discusses a recent IRS private letter ruling granting IRC section 72(b) exclusion ratio treatment for amounts received from an innovative payout option.under a deferred variable annuity.

Description: This article outlines the IRS directive published in July 2014, which provides a safe harbor treatment for variable annuity hedging gains and losses relating to VA contracts issued before Dec. 31, 2009.