Description: The article discusses the practical impact of recently Rev. Rul. 2014-7, which modified and supercedes Rev. Rul. 2007-54 by republishing the position of what variable annuity contract reserves are taken into for tax purposes without addressing the issue of how to calculate required interest for separate accounts; Rev. Rul. 2014-7 also obsoleted Rev. Rul. 2007-61, which had suspended Rev. Rul. 2007-54.

Description: Full version of Taxing Times, September 2007, Volume 3, Issue No. 3.

Description: Full version of Taxing Times, May 2005, Volume 1, Issue No. 1.

Description: A summary discussion of those items listed in the 2012-2013 Priority Guidance Plan issued by the IRS and Treasury that address tax issues of concern to life insurance companies.

Description: Part II of a three part series of articles discussing the extent to which the Internal Revenue Code gives deference to NAIC and state regulatory insurance concepts and rules in insurance classification and accounting concepts for tax purposes.

Description: One of the significant tax benefits of a life insurance contract is that, for purposes of determining the taxable amount of proceeds received under the contract on distributions or surrender,the investment in the contract includes the aggregate amount of premiums, unreduced by the cost of insurance provided IRC section 72c. IRS rules net surrender value reserves must be reduced by a YRT reserve credit.

Description: Company Tax Issues

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of tax reserves computed precisely according to the requirements of the Internal Revenue Code, and the IRS has challenged the reserve deduction. Other sections of this article also cover IRS rulings on the treatment and valuation of an insurance company stock purchased as an asset acquisition and COLI life insurance.

Description: Discussions on CIGNA, SEPP failure, investor control, tacking rule, and split-dollar life insurance arrangement are featured.