Description: The Tidbit summarizes LTRs 201609008 and 201613016 and discusses the definition of insurance under the tax code in light of these new pieces of guidance from the IRS.

Description: The year 1990 was marked by a major tax increase for life insurance companies, introducing the DAC tax, with the passage of the Omnibus Budget Reconciliation Act of 1990. This paper refers to documentation that provides a clear consice summary of the 1990 Tax Act.

Description: The Required Minimum Distribution [RMD] working group of the Taxation Section has completed research in determing the actuarial present value of additional benefits for computing RMD under deferred annuity contracts. This Appendix E spreadsheet is for the Guaranteed Minimum Withdrawal Benefit [GMWB] calculation. See the SOA website research section for the complete report and excel spreadsheet for the other appendices.

Description: Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without any published guidance on when annuity payments can be used to satisfy the SEPP [Substantially Equal Periodic Payments] exceptions to the 10 percent penalty tax under sections 72q2D and 72t2Aiv. This article discusses that problem. The insurance industry requested guidance on this issue.8

Description: On Aug. 11, 2011, the Internal Revenue Service IRS released Notice 2011-68,1 regarding the tax treatment of stand-alone and “combination” longtermcare LTC insurance products. The Notice provides interim guidance on certain issues and requests public comment on others. This article discusses that notice and taxation issues related to Long Term Care products, combination products and long term care riders to annuities.

Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: October issue of Taxing Times

Description: Basic discussion of premiums paid, investment in the contract, and basis as used in IRC provisions applicable to life insurance and annuity contracts.

Description: This article describes the effect of different valuation interest rates and levels of surplus on income tax paid by life insurance companies via Phase 1 of the Federal Income Tax Act of 1959.

Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.