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: After outlining some of the issues involved in the taxation of life insurance companies, this paper describes the tax consequences of various strategic courses of action by life insurance companies. From Transactions of Society of Actuaries 1981, Vol. 33.

Description: In this paper, the author presents the statutory and regulatory rationale for the Internal Revenue Service, ‘IRS,” position on integration. The author discusses the integration requirements under IRC Section 401a which must be met for a private pension plan to receive favorable tax treatment, including the prohibited discrimination requirement. From the 1982 Transactions Vol. 34.

Description: This presentation is a panel discussion from the 1991 Annual Meeting of the Society of Actuaries, held October 20-23 in Toronto. The panelists present the basics of nondiscrimination in pension plans, the provisions of the tax code designed to prevent benefits and contributions from being steered primarily to the higher paid participants in a plan. The panelists discuss the relevant sections of the Internal Revenue Code, including 401[a][4], 410[b], 401[I], 401[a][26], and the recently published regulations. From the Record of Society of Actuaries, Volume 17, No. 4B.

Description: 1992 SOA Regional Meeting, Chicago. This presentation provided a 1992 rulings and regulations update including: 1. Bankruptcy. 2. Pension Benefit Guarantee Corporation update. 3. IRS Announcement 92-29, which extended the effective dates for the 401 a4 and related regulations. 4. IRS Announcement 92-81, which is is the data procedure announcement for 401a4 substantiation. 5. Revenue Procedure 92-42, which, repeals Revenue Procedure 89-45. 6. The Internal Revenue Service business plan.

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.

Description: Section 807d of the IRC provides that the deductible reserve for a life insurance contract is the greater of net surrender value or the Federally Prescribed Reserve FPR calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve exceed “aggregate statutory reserves” i.e., the statutory cap. This article logically concludes that deficiency reserves are included in the calculation of the statutory cap.