Description: This presentation is a concurrent session from the 1991 Meeting of the Society of Actuaries, held April 18-19 in New Orleans. In this life insurance product tax session, attorneys representing the American Council of Life Insurance ACLI, the Internal revenue Service, ‘IRS,’ and the law firm of Davis & Harman discuss the status of recent IRS Private Letter Rulings, current activities of the American Council of Life Insurance, ‘ACLI,’ and other topics including the international reach of Internal Revenue Code sections 7702 and 7702A. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 1.

Description: A discussion of how issuers and providers of IRAs and employer-provided qualified retirement plans need to consider all situations and possibly modify their administrative systems and/or procedures for purposes of administering the IRAs and plans in accordance with the RMD required minimum distribution rules.

Description: Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without any published guidance on when annuity payments can be used to satisfy the SEPP [Substantially Equal Periodic Payments] exceptions to the 10 percent penalty tax under sections 72q2D and 72t2Aiv. This article discusses that problem. The insurance industry requested guidance on this issue.8

Description: On Aug. 11, 2011, the Internal Revenue Service IRS released Notice 2011-68,1 regarding the tax treatment of stand-alone and “combination” longtermcare LTC insurance products. The Notice provides interim guidance on certain issues and requests public comment on others. This article discusses that notice and taxation issues related to Long Term Care products, combination products and long term care riders to annuities.

Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: October issue of Taxing Times

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: A discussion of the proposed safe harbor with respect to calculations for contracts where the insured reaches age 100.

Description: The Internal Revenue Service issued its seminal ruling interpreting Internal Revenal Code section 7702A[c][3][B][i], commonly referred to as the Necessary Premium Test [NPT]. The purpose of the NPT is to shelter certain death benefit increases from material change status, avoiding the 7 pay test's reapplication on their account.

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.