Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: A discussion of the proposed safe harbor with respect to calculations for contracts where the insured reaches age 100.

Description: The Internal Revenue Service issued its seminal ruling interpreting Internal Revenal Code section 7702A[c][3][B][i], commonly referred to as the Necessary Premium Test [NPT]. The purpose of the NPT is to shelter certain death benefit increases from material change status, avoiding the 7 pay test's reapplication on their account.

Description: This article summarizes the government guidance for protected cells in the insurance context and the ABA Recommendation, and comments on the Notice and ABA Recommendation in light of traditional notions of equity ownership for federal corporate income tax purposes.

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.

Description: After outlining some of the issues involved in the taxation of life insurance companies, this paper describes the tax consequences of various strategic courses of action by life insurance companies. From Transactions of Society of Actuaries 1981, Vol. 33.

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: This is an article about how to place value on an annuity benefit.

Description: In this session, panel members speculate about changes to insurance company taxation, policyholder taxation and insurance product taxation in the 1980's. Both U.S. and Canadian viewpoints are shared.