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Rightsizing the Floor Interest Rate Rules of Sections 7702 and 7702A
contracts entered into on and after June 21, 1988.[17] Why the Floor Interest Rates Needed to be Changed ... mortality charge rule of section 7702(c)(3)(B)(i). [17] See § 5012(e)(1) of the Technical and Miscellaneous ...- Authors: Brian King, Craig R Springfield, Robert A Fishbein
- Date: Mar 2021
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance>Pricing - Life Insurance; Life Insurance>Product development - Life Insurance; Life Insurance>Universal life; Life Insurance>Whole life; Public Policy; Public Policy
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New Closing Agreement Procedure for Failed Life Insurance Contracts—Rev. Proc. 2008-40
Prior closing agreement procedures. In Rev. Rul. 91-17, the Service announced that for a limited period ... are similar to those set forth in Rev. Rul. 91-17, although a number of changes have been instituted ...- Authors: Craig R Springfield, Daniela Stoia
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance
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The Perils of Reducing Death Benefits: Private Letter Ruling 201230009
adjustment” for death benefit decreases under this rule.17 order not to disrupt sales of contracts. This ... | FROM PAGE 15 FEBRUARY 2013 TAXING TIMES | 17 however, since the application of the reasonable ...- Authors: John Adney, Craig R Springfield
- Date: Feb 2013
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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On Grandfathers and Adjustments: New IRS Chief Counsel Advice Memo Blurs Lines
Chief Counsel Advice Memorandum 200805022 (Aug. 17, 2007) (the “CCA”), the Service essentially concludes ... “materially changed” on or after a certain date.17 The Service acknowledged that the TAMRA conference ...- Authors: Application Administrator, Craig R Springfield
- Date: May 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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T3: Taxing Times Tidbits
See, e.g., PLR 200339015 (June 17, 2003) and PLR 200339016 (June 17, 2003), both involving critical ... 2 2008-29 I.R.B. 160, amplifying Rev. Rul. 91-17, 1991-1 C.B. 190. Rev. Proc. 2008-42 provides the ...- Authors: Mark E Griffin, Craig R Springfield, Daniela Stoia, Biruta P Kelly
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy; Reinsurance
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Final Regulations Under Sections 101 and 6050Y
responsible for administering the life insurance contract.17 Thus, indem- nity reinsurers that do not administer ... to apply only to FEBRUARY 2020 TAXING TIMES | 17 contracts issued on or before Dec. 31, 1984. Presumably ...- Authors: Craig R Springfield, Kristin R Norberg
- Date: Feb 2020
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Rev. Proc. 2008-39—Correction of Inadvertent MECs: Is the Third Time the Charm?
fail the 7-pay test inadvertently in the future.17 For example, if the cause of the error that resulted ... Requirements : Rev. Proc. 2008-39 … from pg. 17 18 4TAXING TIMES consists of items of information ...- Authors: Craig R Springfield, Daniela Stoia
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance
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Life Beyond 100: Rev. Proc. 2010-28 Finalizes the “Age 100 Methodologies” Safe Harbor
calculating net single premiums and necessary premiums.17 Furthermore, to determine the guide- line level premium ... Rev. Proc. 2010-28, § 1. 16 Id., at § 3.02(a). 17 Id., at § 3.02(b). 18 Id., at § 3.02(c). 19 Id ...- Authors: Application Administrator, Brian King, Craig R Springfield
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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The Second Edition of Life Insurance & Modified Endowments Under Internal Revenue Code Sections 7702 and 7702A
The Second Edition of Life Insurance & Modified Endowments Under Internal Revenue Code ... the mean- ing of IRC § 7702A(a). 4 Rev. Rul. 91-17, 1990-1 C.B. 190; IRC §§ 101(f)(3)(H) and 7702(f)(8) ...- Authors: John Adney, Brian King, Craig R Springfield
- Date: Jun 2015
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Taxing Times, May 2007, Volume 3, Issue No. 2
forward to May 2007 and the countdown is on, with only 17 months to go. As most of our readers are well aware ... funds’ as the term is used in the acts of Congress.”17 Treas. Reg. § 1.801-4(e)(5) would also appear to ...- Authors: Application Administrator, Christian J DesRochers, Edward Robbins, Leslie Chapman, Brian King, Kory Olsen, Frederic Gelfond, Craig R Springfield, Bryan W Keene, Peter Winslow
- Date: May 2007
- Publication Name: Taxing Times