Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

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

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: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: A discussion of the tax-related initiatives listed on the IRS Priority Business Plan for 2010 targeting product tax issues and how they relate to the work of the Taxation Section.

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

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: 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: 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