Description: Article examines a proposed amendment to the MAP-21 Act that would have changed a number of tax requirements regarding so-called life settlements.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

Description: This article provides an alternative method to the computation of the Reduction in Benefits Test under 7702A. Part 1 provided for reduction in death benefits. Part 2 provides for reduction in Qualified Additional Benefits.

Description: This article discusses new tax reporting requirements for transfers for value under section 6050Y. It also discusses changes to the transfer for value rule of section 101(a)(2) and (3), including the definition of a reportable policy sale.

Description: This article discusses final Treasury Regulations published in October 2019 under Internal Revenue Code sections 101 and 6050Y. The regulations cover new tax reporting requirements for transfers and sales of life insurance contracts, as well as changes to the transfer-for-value rules related to reportable policy sales