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 actuarial committee that authored this report developed a model to estimate the revenue the tax would generate. The results point out key considerations for an excise tax on high cost health plans, including the wide range of results generated by sensitivity to certain assumptions.

Description: This paper discusses the following cases: Rudolph V. United States- concerning taxability of agent convention travel, State Board Insurance v. Todd Shipyards Corporation- concerning premium tax for unlicensed insurers, United Services Life Insurance Company v. Delaney- concerning aviation restrictions in a life insurance policy, Metropolitan Life Insurance Company v. Wood- concerning conditional approval, Hartford Live Stock Insurance Company v. Phillips- concerning livestock insurance with an undisclosed pre-existing condition, State Security Life Insurance Company v. Kinter- concerning the due date for monthly premiums to prevent lapsation.

Description: This section presents multiple insurance-related legal cases from 1954: 1. AVIATION EXCLUSlON PILOT: Ezell v. Atlantic Life Insurance Company, 2. LIFE INSURANCE COMPANY FEDERAL INCOME TAX-OIL ROYALTIES AND BONUS: Great National Life Insurance Company v. Campbell, 3. SIMILAR CORPORATE NAMESADMISSlON TO Do BUSINESS IN STATE : United Life Insurance Company v. United Insurance Company, 4. DOUBLE INDEMNITY MILITARY EXCLUSION: Langlas v. Iowa Life Insurance Company, 5. STATUTE REQUIRING COPY OF APPLICATION TO BE ATTACHED-FRATERNAL BENEFIT SOCIETY: Wheeler v. Ben Hur Life Association, 6. BENEFICIARY'S RIGHT TO ASCERTAIN AND TO PAY PREMIUM: American Life Insurance Company v. Hauer, 7. QUARTERLY PREMIUM IN EXCESS OF ONE-QUARTER OF ANNUAL RATE: Cohen v. John Hancock Mutual Life Insurance Company, 8. SETTLEMENT OPTION-TESTAMENTARY DISPOSITION: Hall vs. Mutual Life Insurance Company, 9. DEATH DUTIESLIABILITY OF COMPANY UNDER ANNUITY: Mutual Benefit Life Insurance Company v. Dimond, 10. DELIVERY OF POLICYPOLICY MAILED TO AGENT: Mid-Continent Life Insurance Company vs. Dees,

Description: Small Talk Newsletter, June 2005, Issue No. 24. Last fall, the Internal Revenue Service IRS released Notice 2004-61, 2004-41 I.R.B. 596 October 12, 2004, interpreting the reasonable mortality charge requirement applicable to life insurance contracts under Section 7702 of the Internal Revenue Code.

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: Overview of latest developments on IRC Section 7702, IRC Section 848, market value adjusted contracts, companies in rehabilitation and Canadian issues including: • Part I income tax • Part IV capital tax

Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.

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.