Description: A discussion on technology improvements in establishing compliance with sections 7702 and 7702A. The Internal Revenue Code defines life insurance using actuarial tests that limit the investment in a life insurance contract as compared to the death benefit. Inadvertant failures of the actuarial tests can be uncovered by testing in order to enable remediation.

Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).

Description: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.