Description: Current tax issues affecting the insurance industry, including the Inflation Reduction Act (Budget Reconciliation Bill)'s tax provisions, including the corporate minimum book income tax and share repurchase (or stock buyback) excise tax; the tax treatment of non coordinated benefits (also known as fixed indemnity benefits); and an update on the OECD’s Base Erosion and Profit Shifting Project

Description: Provides information on Section 7702 mortality requirements, the implications of the adoption of the 2017 CSO tables and the need for IRS guidance.

Description: Tells what occurred after the adverse private letter ruling PLR 200738016 up to the issuance of the revenue procedure, and offers some speculation about the future.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: This article begins with a brief review of the general requirements of section 7702A and the consequences of MEC status for a life insurance contract and continues with a description of the evolution of the inadvertent MEC correction procedures over the past near decade.

Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.