Description: Guy Thomas develops the theory of “loss coverage,” which is a measure of the extent to which potentially insurable losses are actually compensated by insurance. His main points of difference are: a) Adverse selection in insurance is usually weaker that most commentaries suggest … b) From a public, policy perspective, ‘weak’ adverse selection in insurance is a good thing. … c)… some restrictions on risk classification are a good thing in some insurance markets

Description: This article discusses new tax reporting requirements for transfers for value under section 6050Y. It also discusses changes to the transfer for value rule of section 101(a)(2) and (3), including the definition of a reportable policy sale.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.