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: The Society of Actuaries will be offering this webinar series intended to educate and investigate aspects of life insurance, annuity, and long-term care product tax compliance. Developed by the Taxation Section, participants will be brought up to date on recent Internal Revenue Service (IRS) guidance and learn about the newest tax issues related to product design and administration. Legal, IRS and product development experts will provide vital insights into the challenges of developing and administering products within the requirements of the Internal Revenue Code (IRC) and allow ample opportunities for questions and information exchange. This session will feature legal, tax, actuarial and compliance experts. Recent legislative changes will be emphasized, including the Secure Act/Secure Act 2.0 and other items/questions that experts have seen increased industry activity.

Description: The Society of Actuaries will be offering this webinar series intended to educate and investigate aspects of life insurance, annuity, and long-term care product tax compliance. Developed by the Taxation Section, participants will be brought up to date on recent Internal Revenue Service (IRS) guidance and learn about the newest tax issues related to product design and administration. Legal, IRS and product development experts will provide vital insights into the challenges of developing and administering products within the requirements of the Internal Revenue Code (IRC) and allow ample opportunities for questions and information exchange. This session will feature legal, tax, actuarial and compliance experts. Recent legislative changes will be emphasized, including the Secure Act/Secure Act 2.0 and other items/questions that experts have seen increased industry activity.