Description: Overview of latest developments on IRC Section 7702, IRC Section 848, market value adjusted contracts, companies in rehabilitation and Canadian issues including: • Part I income tax • Part IV capital tax

Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: Small Talk Newsletter, June 2005, Issue No. 24. Last fall, the Internal Revenue Service IRS released Notice 2004-61, 2004-41 I.R.B. 596 October 12, 2004, interpreting the reasonable mortality charge requirement applicable to life insurance contracts under Section 7702 of the Internal Revenue Code.

Description: The panel provided a basis for discussing the implications of the new tax code to life insurance and associated products, including annuities and accident and health insurance, but no discussion of the taxation of insurance companies.

Description: This 2008 supplement addresses the issues that have arisen in life insurance tax laws related to IRC 7702 and 7702A since the book was published in 2004. It also enhances and clarifies issues that were addressed in the text, adding detail and further discussion.

Description: Guidance and interpretation regarding reasonable mortality charge requirement of Section 7702, based from IRS Notice 2004-61, 2004-41 I.R.B. 596 of October 12, 2004.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.

Description: This presentation is a panel discussion, session 46PD, from the 2004 Spring Meeting of the Society of Actuaries, held June 14-15 in San Antonio, TX. The panelists, industry and tax leaders, discuss recent, ongoing and potential issues, including initiatives affecting various products and markets, including corporate-owned life insurance [COLI] and business-owned life insurance [BOLI] issues, as well as some of the recent guidance that's been issued that affects Section 412[i] plans. Other topics are Internal Revenue Code Sections 7702 and 7702A, and the 2001 CSO Mortality Table. Discussion from participants is included. From the Record of Society of Actuaries, Volume 30, No. 2.

Description: In session 75 PD of the New York Annual Meeting panelists explore practical considerations of maintaining compliance with federal income tax definition of life insurance rules. From the Record of the Society of Actuaries, Vol. 24, No. 3.

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.