Description: The article discusses court decisions on the tax basis and taxable gain in life insurance contracts.

Description: Description of general tax consequences of purchasing an insurance company, either through buying the assets or buying the stock.

Description: Discusses the Age 100 safe harbor methodologies in the 2010 IRS revenue procedure, and then provided some considerations that insurers should keep in mind in applying these methodologies.

Description: A discussion of, first, the three-year transition period for adopting principle-based reserves and how it might not apply to tax reserves, and second, the tax impact of adding investment options to in-force contracts.

Description: This article discusses new tax reporting requirements for transfers for value under section 6050Y. It also discusses changes to the transfer for value rule of section 101(a)(2) and (3), including the definition of a reportable policy sale.

Description: The rules governing the tax treatment of distributions from life insurance or annuity contracts are complex. Worse, the relevant IRC section, section 72, seems at times to be the product of a conspiracy in restraint of understanding.

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

Description: Update on a broad range of insurance and investment tax matters upon which ACLI is working, including: deficiency reserve guidance, IRS guidance on PBR/AG 43, Camp Financial Product Discussion Draft, FATCA and changes to non-forfeiture laws due to low interest rates

Description: Discusses the CCA 201939003 and the conclusions that were made and the impacts it has on a taxpayer's ability to make an election for determining the interest rate used to compute tax-deductible life insurance reserves.

Description: A discussion of the American Financial case in detail. Also includes background on what the statute requires and the Internal Revenue Service (IRS)’s ruling and litigating positions.