Description: This session discussion is about SPWL: Is a modified endowment product salable, 7 pay: What sales applications are working best and pricing and administrative compliance issues. From Record of the Society of Actuaries Vol. 15, No. 2A.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: This is a discussion of the paper, Actuarial Note: Valuation of Reversionary Interests Involving Two or More Lives for Federal Tax Purposes by Charles G. Groeschell and William M. Snell. From Transactions of Society of Actuaries 1951, Vol. 3, No. 7.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

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: 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: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

Description: A discussion of the PLR that addresses a Wellness Rider that an affiliated group of life insurance companies proposed to offer only on a prospective basis with newly issued life insurance contracts.

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