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: A discussion of the proposed safe harbor with respect to calculations for contracts where the insured reaches age 100.

Description: The article summarizes the new net investment income tax proposed regulations recently published by the IRS as they relate to life insurance and annuity contracts.

Description: The article provides an overview of the federal tax treatment of long-term care insurance contracts, including a brief history of the tax treatment of long-term care insurance, the requirements that must be satisfied in order to be treated as qualified long-term care insurance under the Internal Revenue Code, and a brief discussion of qualified long-term care combination products and chronic and terminal illness accelerated death benefits offered under life insurance contracts.

Description: Discussion of private letter tax rulings on the definition of Cash Surrender Value for purposes of interpreting the definition of life insurance for the policyholder's taxation of the contracts.

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.