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: Summary of the upcoming activities for the Smaller Insurance Company Section in 2016.

Description: This discussion at the SOA 1967 Annual Meeting covers three topics. First is the Carter Commission Report that recommends radical changes to the Canadian tax system. Second is a report on U.S. federal government activities in the health market. Third is an update on variable annuities.

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