Description: Tells what occurred after the adverse private letter ruling PLR 200738016 up to the issuance of the revenue procedure, and offers some speculation about the future.

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: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

Description: This article argues that wealth managers should advocate dynamic spending in proportion to survival probabilities, adjusted up for exogenous pension income and down for longevity risk aversion. The authors criticize the rule of thumb of spending a fixed 'x' percent of assets for retirement planning purposes.