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

Description: This article considers PLR 201304003, which addressed the application of Internal Revenue Code section 1035 to the exchange of a survivorship, or “second-to-die,” life insurance contract after the death of one of the insureds for a new life insurance contract covering only the life of the surviving insured.

Description: Insurance companies will be required to file the Internal Revenue Service IRS Schedule M-3 for tax years ending on or after Dec. 31, 2006. Schedule M-3 was designed by the IRS as a replacement for the Schedule M-1, which is used to reconcile a corporation's financial accounting income or loss with its taxable income or loss.

Description: The article discusses recently-issued regulations under section 807 of the Internal Revenue Code, concerning the computation and reporting of reserves. The provisions addressed generally relate to the Tax Cuts and Jobs Act of 2017.

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

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: 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: 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: This article is a general discussion about prior correction procedures for failed life insurance contracts and the new IRS procedure for remediation.