Description: Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without any published guidance on when annuity payments can be used to satisfy the SEPP [Substantially Equal Periodic Payments] exceptions to the 10 percent penalty tax under sections 72q2D and 72t2Aiv. This article discusses that problem. The insurance industry requested guidance on this issue.8

Description: Presented at October 1985 Annual Meeting. Discusses proposals for changing the tax law with respect to the taxation of personal income: The tax climate that led to these proposals, A description of the major proposals including the Treasury proposal pending in Congress, How these proposals will affect the design, marketing and sale of individual life and annuity products.

Description: Primer on the federal income taxation of nonqualified annuities

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: Presented at May 1996 Spring Meeting. This session addresses potential changes in life insurance and annuity markets under alternative tax systems, that is, value-added tax 'VAT' or consumption taxes, and flat taxes and the impact of those changes.

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.

Description: This article discusses the temporary waiver and how it provides only limited relief from the section 401a9 minimum distribution requirements.

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.