Description: Overview of articles in the October 2013 issue of TAXING TIMES.

Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

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: T3: TAXING TIMES TIDBITS

Description: Guidance and interpretation regarding reasonable mortality charge requirement of Section 7702, based from IRS Notice 2004-61, 2004-41 I.R.B. 596 of October 12, 2004.

Description: Small Talk Newsletter, June 2005, Issue No. 24. Last fall, the Internal Revenue Service IRS released Notice 2004-61, 2004-41 I.R.B. 596 October 12, 2004, interpreting the reasonable mortality charge requirement applicable to life insurance contracts under Section 7702 of the Internal Revenue Code.

Description: A recent list of government publications announces the publication of a volume entitled Actuarial Values I: Valuation of Last Survivor Charitable Remainders-Part B-Two-Life Tables for Untirusts and Pooled Income Funds - Internal Revenue Service Publication 7233 11-71 available from the Superintendent of Documents, U. S. Government Printing Office, Washington, D. C. 20402 for $4.50. The article outlines the actuarial formulas used in determining the tables used by the IRS.

Description: Almost 65 years ago, the Supreme Court issued its opinion in Helvering v. Le Gierse, addressing when an arrangement should be recognized as involving “insurance” for federal income tax purposes. According to the Court, an “insurance risk” must be present, and for an insurance risk to exist, there must be “risk-shifting and risk distribution.”

Description: Notice 2004-611 is the latest in a series of administrative pronouncements from the Internal Revenue Service related to the appropriate mortality assumptions to be used in computing the definitional limitations under Internal Revenue Code Section 7702 and the seven-pay limitation under the Section 7702A modified endowment rules.

Description: Read the February 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.