Description: Article examines a proposed amendment to the MAP-21 Act that would have changed a number of tax requirements regarding so-called life settlements.

Description: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

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: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.