Description: The article provides an overview of the federal tax treatment of long-term care insurance contracts, including a brief history of the tax treatment of long-term care insurance, the requirements that must be satisfied in order to be treated as qualified long-term care insurance under the Internal Revenue Code, and a brief discussion of qualified long-term care combination products and chronic and terminal illness accelerated death benefits offered under life insurance contracts.

Description: A discussion of how the tax law changes of 2003 might affect the attractiveness of variable annuity business relative to mutual funds and direct investments in dividend paying equities.

Description: A discussion of Section 7702 and age 100 insured and the need for guidance on combined annuity and long-term care contracts

Description: This article discusses several issues related to the IRS and taxation. These include partial exchanges of non-qualified annuity contracts, Long Term Care features on Annuity or Life contracts, and the applicability of the Foreign Account Tax Compliance Act [FATCA] to Life Insurance Campanies and products.

Description: A discussion about the taxation of life insurance companies and affiliated products and the ramifications it has annuity contracts and long-term care.

Description: On Aug. 11, 2011, the Internal Revenue Service IRS released Notice 2011-68,1 regarding the tax treatment of stand-alone and “combination” longtermcare LTC insurance products. The Notice provides interim guidance on certain issues and requests public comment on others. This article discusses that notice and taxation issues related to Long Term Care products, combination products and long term care riders to 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Description: The Phase 3 tax is the description given to the federal income tax imputable to amounts withdrawn from the Policyholders Surplus Account maintained under the federal income tax law. This article discusses certain facets of the federal income Phase 3 tax as it relates to these withdrawals. Still significant for a large health insurer that has been in existence since before 1984 should health care become nationalized.

Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: On Nov. 2, 2018, the Internal Revenue Service (IRS) released Technical Advice Memorandum 201844009 (the TAM).