Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: This 1977 panel discussion examined individual tax qualified products. Areas covered included: 1. Regulatory developments 2. Products being used 3. Effect of the current money market on product design 4. Assumptions 5. Results by market 6. Spousal IRA's

Description: This 1980 session covers amendments to the SNL and SVL and the anticipated revision to the CSO Mortality Table. Questions discussed: 1. What changes can be expected in requirements in the1980's? 2. What changes in products design will likely emerge from these? 3. What will be the effect on future gross premium, cash value, and reserve levels? 4. Will these changes be compatible with all economic forecast scenarios? 5. Will these changes create a need for increased gross premium rates or for higher company surplus levels? 6. Should attention to solvency measures be increased? 7. Are the allowable valuation interest rates sufficiently liberal?

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.