Description: This presentation is a concurrent session from the 1991 Meeting of the Society of Actuaries, held April 18-19 in New Orleans. In this life insurance product tax session, attorneys representing the American Council of Life Insurance ACLI, the Internal revenue Service, ‘IRS,’ and the law firm of Davis & Harman discuss the status of recent IRS Private Letter Rulings, current activities of the American Council of Life Insurance, ‘ACLI,’ and other topics including the international reach of Internal Revenue Code sections 7702 and 7702A. Discussion from participants is included. From the Record of Society of Actuaries, Volume 17, No. 1.

Description: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.

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: 1992 SOA Regional Meeting, Anaheim. This session addressed tax compliance, the tax consequences of life insurance contract failure, the correction of failed contracts, and a 1992 update on the proposed deferred acquisition cost tax regulations.

Description: This 2008 supplement addresses the issues that have arisen in life insurance tax laws related to IRC 7702 and 7702A since the book was published in 2004. It also enhances and clarifies issues that were addressed in the text, adding detail and further discussion.

Description: This presentation is a panel discussion, session 46PD, from the 2004 Spring Meeting of the Society of Actuaries, held June 14-15 in San Antonio, TX. The panelists, industry and tax leaders, discuss recent, ongoing and potential issues, including initiatives affecting various products and markets, including corporate-owned life insurance [COLI] and business-owned life insurance [BOLI] issues, as well as some of the recent guidance that's been issued that affects Section 412[i] plans. Other topics are Internal Revenue Code Sections 7702 and 7702A, and the 2001 CSO Mortality Table. Discussion from participants is included. From the Record of Society of Actuaries, Volume 30, No. 2.

Description: A discussion of the proposed safe harbor with respect to calculations for contracts where the insured reaches age 100.

Description: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

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.

Description: This article discusses the implications of a principle-based reserve PBR system with respect to federal income taxation of life insurance companies, particularly with respect to tax reserves and their deductibility for tax purposes. The article discusses potential problems with existing tax rules for reserve deduction, what courses of action the IRS could take, and suggestions for design features of a PBR approach that would make it more consistent with current tax rules. Life insurance product tax implications are also discussed.