Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: This article delves into a new line of statistical thinking of the author, that may be useful for product development actuaries. The key concept is how product design can produce products that diversify quickly, meaning that the company can be confident of a profitable product line, based on fewer sales than might be true for other designs.