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: 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: 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.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

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

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: Discusses PLR 201105012, the investor control doctrine, and how the IRS concluded that shares of a Lifecycle Fund, available only through a life insurance company's separate account, still can be considered owned by the insurer and not the policyowner for federal income tax purposes even if it at least partly invests in shares of public funds.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.

Description: Tidbits relate to contingent deferred annuities, wellness benefits in qualified long-term care contracts, and reactivating the active financing exception for insurance companies.