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

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: Read the February 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: This paper points out errors in the Graetz Prepayment Analysis used to determine tax liability for mutual companies. Those errors result in an understatement of the tax burden borne by mutual life insurance companies. The Graetz prepayment analysis was advanced as a justification for repealing Section 809 of the Internal Revenue Code. Correcting the errors in the Graetz prepayment analysis strengthens the argument for repeal.

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.