Description: This article discusses the structure of and the dangers posed by Stranger-Originated Life Insurance STOLI.

Description: This article begins with a brief review of the treatment of QAB charges under the Code and the guidance the Internal Revenue Service the “Service” has issued regarding the manner in which taxpayers should account for QAB charges Part I. It then describes Rev. Rul. 2005-6’s three alternatives for addressing improper accounting for QAB charges Part II. It also includes a discussion about an Alternative C closing agreement.

Description: Read the Quo Vadis Reinsurance.

Description: The paper describes a cost-benefit analysis to determine the value of electronic health records (EHRs) in life insurance accelerated underwriting programs. Sample cases from a carrier were underwritten pre-EHR and post-EHR and the mortality savings estimates from risk class changes using EHRs was compared to procurement costs. Results were developed to cover a range of scenarios. Factors to consider for carriers evaluating the cost-effectiveness of using EHRs in their own accelerated underwriting programs are also described.

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

Description: Description and welcome to the 2020 Canadian Reinsurance Conference including highlight of the key note speaker

Description: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.

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: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.