Description: Presented at May 1996 Spring Meeting. This session addresses potential changes in life insurance and annuity markets under alternative tax systems, that is, value-added tax 'VAT' or consumption taxes, and flat taxes and the impact of those changes.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

Description: Presented at April 1985 April Meeting. This session discussed: Annuities, Non-participating life products, Participating life products, Variable products

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: 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 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: A discussion of how the tax law changes of 2003 might affect the attractiveness of variable annuity business relative to mutual funds and direct investments in dividend paying equities.

Description: This article discusses the temporary waiver and how it provides only limited relief from the section 401a9 minimum distribution requirements.