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 article discusses two IRS private letter rulings addressing the application of the section 72(s) after death distribution requirements to joint-life GLWBs covering non-spouses. The article explores the legal basis for the IRS conclusion and the potential utility of the distribution method approved by the ruling.

Description: The article discussing the differing tax definitions of life insurance in the US and Canada and relates them to new international tax reporting regimes such as FATCA.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

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

Description: Taxing Times, September 2006, Volume 2, Issue No. 2.

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

Description: On June 26, 2013, the Supreme Court released its decision in the case of United States v. Windsor, Executor of the Estate of Spyer, et al. addressing the constitutionality of the federal Defense of Marriage Act (“DOMA”). This article explores the implications for life insurance and annuity contract spousal provisions that are governed by federal law.

Description: A discussion of the theoretical basis of deferred income tax accounting (accounting for actuaries), an overview of the current statutory accounting rules governing income tax accounting under SSAP 101, and some examples of the effects of SSAP 101’s admissibility test on regulatory capital.

Description: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.