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.

Description: Highlights of recent activities of the Taxation Section

Description: In this session, panel members speculate about changes to insurance company taxation, policyholder taxation and insurance product taxation in the 1980's. Both U.S. and Canadian viewpoints are shared.

Description: Presented at May 1985 Spring Meeting. This session discussed: Overview of tax changes for different types of life insurers, Product impact by type of product, Implementation issues - calculating tax reserves, Tax planning implications.

Description: Presented at October 1985 Annual Meeting. Discusses proposals for changing the tax law with respect to the taxation of personal income: The tax climate that led to these proposals, A description of the major proposals including the Treasury proposal pending in Congress, How these proposals will affect the design, marketing and sale of individual life and annuity products.

Description: Article from The Actuary, December 1971 – volume 5 - Issue 10 that talks about tax laws and regulations. In particular, this article discusses the formula, developed by Charles T. Kemmerer, for calculating the remainder interest in a charitable remainder unitrust which falls on the death of the survivor of two or more persons.

Description: This is an article about how to place value on an annuity benefit.