Description: The article discusses the impact of changes made to Internal Revenue Code Section 7702 by the ConsolidatedAppropriations Act, 2021. The Consolidated Appropriations Act made changes to the interest rates used calculatethe Section 7702 premium and cash value funding limitations for life insurance contracts

Description: A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed regulations and legislation to raise tax revenue.

Description: The presenters will discuss recent developments related to the federal qualification and taxation of life insurance and annuity contracts. Among other topics, there will be a focus on comparing and contrasting life insurance product qualification in the U.S. under IRC sections 7702 and 7702A versus qualification in Canada under the 'exempt test' of the Income Tax Act, which has been revised in recent years. Discussion will include comparisons of Canadian provisions to U.S. definition of life insurance and Modified Endowment Contract concepts.

Description: The article focuses on the policyholder tax considerations specific to various types of contracts sold by life insurance companies. When evaluating merger and acquisition or reinsurance transactions, buyers need to be aware of the product tax compliance (PTC) requirements and evaluate any associated risks

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

Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: This article discusses two recent 2005 IRS private letter rulings that involved the meaning of “cash surrender value” as used under code section 7702, which defines a life insurance contract for federal income tax purposes.

Description: This article is a discussion of the proposal to tax the inside build-up in life insurance policies and the consequences if it were to be adopted.

Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.