Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

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

Description: The panel provided a basis for discussing the implications of the new tax code to life insurance and associated products, including annuities and accident and health insurance, but no discussion of the taxation of insurance companies.

Description: Discussion of private letter tax rulings on the definition of Cash Surrender Value for purposes of interpreting the definition of life insurance for the policyholder's taxation of the contracts.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

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 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: 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 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.