Description: A discussion of the three private letter rulings addressing the tax treatment of group insurance contingent annuity contracts providing guaranteed minimum withdrawal benefits linked to an investment account released by the Internal Revenue Service.

Description: Summarizes IRS private letter ruling PLR 200818018, released Jan. 29, 2008, related to treatment of certain payments under Immediate VAs as SEPPs, and discusses its significance.

Description: A discussion of tail-design LTC riders for annuities and how contract cash values are offset by reductions to the annuity contract. LTC benefits, and how they relate to the annuity contracts, are also discussed.

Description: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

Description: The Society of Actuaries are once again offering a seminar that investigates all 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 networking, questions and information exchange.September 12The optional “boot camp” will provide an intense introduction to the basics of product taxation. The boot camp will include sessions focused on life insurance, annuities, and long-term care combination products. The basis of the boot camp will be the authoritative textbooks, “Life Insurance and Modified Endowments Under IRC Sections 7702 and 7702A” and the “Annuities Answer Book.” Book authors will conduct these optional programs. September 13–14The general sessions will feature product, tax, legal and compliance experts as well as Internal Revenue Service (IRS) representatives. Recent changes in the qualification requirements of insurance products and a host of product tax issues beyond Internal Revenue Code (IRC) section 7702 and 7702A will be emphasized.

Description: Discusses Internal Revenue Service Ruling 2011-9. Since ruling now applies to all taxpayers, not just the taxpayer in a prior private letter ruling, taxpayers that have taken a contrary position in past tax years may need to amend prior tax returns.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: Clarification of the tax treatment of non-qualified deferred annuities that are “partially annuitized” is discussed in detail in this article.

Description: Discusses earlier IRS rulings on Contingent Deferred Annuities and the latest ones, PLRs 201117012 and 201117013. Highlights two important additional issues covered in latest rulings.