Description: The presenters will discuss recent developments related to the federal qualification and taxation of life insurance and annuity contracts. Among other topics, there will be a focus on comparing and contrasting life insurance product qualification in the U.S. under IRC sections 7702 and 7702A versus qualification in Canada under the 'exempt test' of the Income Tax Act, which has been revised in recent years. Discussion will include comparisons of Canadian provisions to U.S. definition of life insurance and Modified Endowment Contract concepts.

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

Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: This editorial highlights the hot topics happening in the tax industry today.

Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].

Description: The article focuses on the policyholder tax considerations specific to various types of contracts sold by life insurance companies. When evaluating merger and acquisition or reinsurance transactions, buyers need to be aware of the product tax compliance (PTC) requirements and evaluate any associated risks