Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: The author discusses some common myths about Congress’ tax policy under the 1984 Act that he would like “to debunk.”

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.

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

Description: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.

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 article details the IRS' Revenue Ruling 2005-6. This ruling provides formal guidance on how to treat family term riders for purposes of the computational limit calculations in Internal Revenue Code IRC sections 7702 and 7702A i.e., calculations of net single premiums, guideline single premiums, guideline level premiums and 7-pay premiums. From Small Talk Newsletter, June 2005, Issue No. 24.

Description: Article from The Actuary, December 1986 – Volume No. 20, Issue No. 10 that talks about The Tax Reform Act of 1986.