Description: A discussion of the tax-related initiatives listed on the IRS Priority Business Plan for 2010 targeting product tax issues and how they relate to the work of the Taxation Section.

Description: A discussion of the many developments affecting taxation of life insurance companies and products.

Description: This article examines a recent Technical Advice Memorandum (TAM 201149021) in which the IRS concluded that residual value insurance was not insurance for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied produced a distortion in the insurer's income.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.

Description: The Chairperson of the Taxation Section discusses how the section will deal with changes to the US Tax Code.

Description: This article discusses XXX reserve financing, one of the most common life insurance industry capital markets funding transactions.

Description: An interview with William J. Wilkins, Chief Counsel for the Internal Revenue Service and the Assistant General Counsel in the Department of the Treasury.

Description: In September 2009, the Internal Revenue Service IRS released a private letter ruling PLR 200939018 June 18, 2009 addressing a contract in which the right to receive annuity payments and otherwise access a contract’s cash value is contingent upon the annuitant living to a specified age. The ruling holds that the contract is an annuity contract for purposes of section 72 of the Code. This article reviews the specifics of the ruling.

Description: A discussion of the three private letter rulings addressing the tax treatment of group insurance contingent annuity contracts providing guaranteed minimum withdrawal benefits linked to an investment account released by the Internal Revenue Service.

Description: An explanation of the reasons why the IRS should rule on the application of section 351 to the transfer of assets and reserves in an indemnity coinsurance transaction where the ceding company transfers more assets to the assuming company than it would in an arms-length transaction and, therefore, the ceding company actually receives or is deemed to receive stock in the exchange for the transferred assets including the value of insurance in force. We also will summarize other interesting rulings in the PLR.