Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: From the 1960 Transactions Vol. 12 No. 32, this ‘Discussion of Subjects of Special Interest’ addresses the Life Insurance Company Income Tax Act of 1959.

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: 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: The author discusses some common myths about Congress’ tax policy under the 1984 Act that he would like “to debunk.”

Description: This paper examined two interrelated aspects of federal income taxation of life insurance companies. First, a common-sense approach to the Life Insurance Company Income Tax Act of 1959 was developed. Second, marginal tax rates for Phase III companies was developed.

Description: The Revenue Act of 1987 amended section 807d2B of the Internal Revenue Code. It established the interest rate used in the calculation of tax reserves to be the greater of the applicable federal interest rate or the prevailing maximum statutory valuation rate for the contract’s calendar year of issue. The amendment is effective for contracts issued in tax years beginning after December 31, 1987. This document shows all the applicable federal interest rates from 1998 - 2009.

Description: This article details the IRS' Revenue Ruling 2005-6. This ruling provides formal guidance on how to treat family term riders for purposes of the computational limit calculations in Internal Revenue Code IRC sections 7702 and 7702A i.e., calculations of net single premiums, guideline single premiums, guideline level premiums and 7-pay premiums. From Small Talk Newsletter, June 2005, Issue No. 24.

Description: Article from The Actuary September 1989 – Volume 23, No. 8 discusses TAMRA: the U.S. Technical and Miscellaneous Revenue Act of 1988.

Description: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.