Description: This article provides an overview of the Regs and highlights important open issues regarding determination of a U.S. shareholder’s GILTI amounts.

Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: An overview of bias and fairness in machine learning models, as they apply to use cases in life insurance.

Description: Summary of the December 2003 NAIC Meeting

Description: This article provides a basic introduction to the taxation of qualified annuities held in qualified retirement plans and IRAs. The article has been updated for the SECURE Act and the SECURE 2.0 Act. The article describes the basic types of employer-based plans, provides of overview of the taxation of contributions and benefits when annuities are held in connection with plans and IRAs, explains the required minimum distribution rules, and offers a brief introduction to recent legislation impacting qualified annuities.

Description: Update on Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: This article discusses the structure of and the dangers posed by Stranger-Originated Life Insurance STOLI.

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 a summary of selected sessions of the October 2010 NAIC meeting.

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.