Description: On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine in Webber v. Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets supporting a variable life insurance contract purchased through a private placement transaction. In the end, however, the Webber court leaves a lot of questions unanswered—most significantly, the elusive answer to how to define investor control. This article examines the Investor Control Doctrine, as explained and applied by the U.S. Tax Court in Webber, and considers some of the open questions that remain after June 30, 2015.

Description: Administration system updates and conversions. Legacy systems and their associated problems. Continued low interest rates and in-force policy management actions affecting policyholder behavior. These are but a few of the taxation challenges facing insurers managing the growing complexity of their businesses.<p> Presenters will consider these and other product taxation-related issues, highlighting ways insurers have sought to address them, their impacts, and potential mitigation strategies

Description: This article is a discussion of the proposal to tax the inside build-up in life insurance policies and the consequences if it were to be adopted.

Description: This presentation is a panel discussion, session 46PD, from the 2004 Spring Meeting of the Society of Actuaries, held June 14-15 in San Antonio, TX. The panelists, industry and tax leaders, discuss recent, ongoing and potential issues, including initiatives affecting various products and markets, including corporate-owned life insurance [COLI] and business-owned life insurance [BOLI] issues, as well as some of the recent guidance that&#39;s been issued that affects Section 412[i] plans. Other topics are Internal Revenue Code Sections 7702 and 7702A, and the 2001 CSO Mortality Table. Discussion from participants is included. From the Record of Society of Actuaries, Volume 30, No. 2.

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: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.