Description: On Nov. 2, 2018, the Internal Revenue Service (IRS) released Technical Advice Memorandum 201844009 (the TAM).

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: Update on industry action on legislative and tax regulatory items affecting the life insurance industry.

Description: The U.S. Technical and Miscellaneous Revenue Act of 1988 has created a very significant administrative problem for companies having a large block of “grandfathered” universal life business. The problem is that seemingly harmless future changes in benefits are categorized as “material changes,” causing a policy to lose its grandfather status and subjecting it to the “modified endowment” rules.

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: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].

Description: This article summarizes the government guidance for protected cells in the insurance context and the ABA Recommendation, and comments on the Notice and ABA Recommendation in light of traditional notions of equity ownership for federal corporate income tax purposes.

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.

Description: Updated discussion of IRS Proposed Regulations under Section 162(m)(6), their potential impact upon the life insurance industry, and a 2 percent de minimis exception.