Description: Discusses why it is so important for actuaries to actively monitor evolving issues with taxation of life insurance companies and products, and how to monitor the issues and get involved with the process.

Description: This article details the IRS' Revenue Ruling 2005-6. This ruling provides formal guidance on how to treat family term riders for purposes of the computational limit calculations in Internal Revenue Code IRC sections 7702 and 7702A i.e., calculations of net single premiums, guideline single premiums, guideline level premiums and 7-pay premiums. From Small Talk Newsletter, June 2005, Issue No. 24.

Description: This article discusses the impact on the policyholders and the insurance companies of the phase-out of the deductibility of policy loan interest resulting from the new tax law.

Description: This article discusses the the 1998 alternartive XXX model regulations and the potential tax impact on the definition of life insurance and on reserve deductions associated therewith.

Description: Discussion of recent developments in the taxation of noncoordinated benefits such as fixed indemnity, hospital indemnity, and specified disease insurance policies. Developments include a recent Chief Counsel Advice Memorandum and proposed triagency rulemaking that would impact non coordinated benefits.

Description: Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without any published guidance on when annuity payments can be used to satisfy the SEPP [Substantially Equal Periodic Payments] exceptions to the 10 percent penalty tax under sections 72q2D and 72t2Aiv. This article discusses that problem. The insurance industry requested guidance on this issue.8

Description: The article discusses the impact of changes made to Internal Revenue Code Section 7702 by the ConsolidatedAppropriations Act, 2021. The Consolidated Appropriations Act made changes to the interest rates used calculatethe Section 7702 premium and cash value funding limitations for life insurance contracts

Description: An explanation of the reasons why the IRS should rule on the application of section 351 to the transfer of assets and reserves in an indemnity coinsurance transaction where the ceding company transfers more assets to the assuming company than it would in an arms-length transaction and, therefore, the ceding company actually receives or is deemed to receive stock in the exchange for the transferred assets including the value of insurance in force. We also will summarize other interesting rulings in the PLR.

Description: This article is a discussion of the proposal to tax the inside build-up in life insurance policies and the consequences if it were to be adopted.

Description: IRS published final regulations on updated life expectancy and distribution period tables used for determining RMDs. The article intends to provide an overview on the development of the final regulations and highlight the key updates in final regulations, the transition rules to apply final regulations and some of the relevant issues not addressed in final regulations (e.g. MITT, Rev. Rul. 2002-62 and Notice 2004-15). The article also briefly discusses what financial institutions and actuaries would like to do before the regulations become effective on Jan. 1, 2022.