Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: The Internal Revenue Service issued its seminal ruling interpreting Internal Revenal Code section 7702A[c][3][B][i], commonly referred to as the Necessary Premium Test [NPT]. The purpose of the NPT is to shelter certain death benefit increases from material change status, avoiding the 7 pay test's reapplication on their account.

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: Section 818c of the Life Insurance Company Income Tax Act of 1959 provides, for companies holding other than net level premium reserves, a choice of two methods: exact revaluation or approximate revaluation to this basis. This paper discusses the impact of the choice on the level of a company's tax reserves. A discussion paper follows.

Description: A discussion of spousal provisions that are governed by federal income tax law, specifically the difference between some state laws and the Defense of Marriage Act DOMA.

Description: From a session at a meeting of the Society of Actuaries held in San Diego, CA, June 22-23, 2000 This discussion reviews the need for and a process for remediation of errors made with respect to an inadvertent non-egregious failure to comply with the modified endowment contract rules under Internal Revenue Code Section 7702A.

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: 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: Primer on the federal income taxation of nonqualified annuities

Description: Presented at October 1996 Annual Meeting. Accruals in nonqualified retirement plans have become subject to FICA taxation. In this session, IRS rules are discussed in detail with emphasis on options available for good faith years through 1996 and final regulation years starting in 1997.