Description: This session discussion is about what practitioners have been doing with the new Internal Revenue Code Section 410b and Section 401a26, how have they been doing and comparability calculations for the above. From Record of the Society of Actuaries Vol. 15, No. 1.

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: This paper was written to demonstrate that universal life and indeterminate premium products are similar to participating plans. Followed by several discussion papers submitted.

Description: After the 1986 tax-reform legislation, SPWL currently enjoys a tax treatment preferential to many other financial products. The author suggests that this distinction may not last long.

Description: This article comments on a 1972 paper on the same subject by John Fraser, which made a very careful analysis of the relation between the current earnings rate and the taxable interest. The author builds on Fraser’s illustrative calculations, which showed clearly that there was an optimal spread between the current earnings rate and the assumed reserve interest rate to produce the maximum interest deduction, by including an analysis of the after-tax yield effect.

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.