Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

Description: A discussion of funding arrangements that can reduce the costs of providing medical coverage through lower reserves or state tax savings, instead of through cutting benefits.

Description: This paper develops an analytical method for evaluating the utility of tax-planning activities that cause initial statutory surplus strain and expands the horizon beyond normal pricing applications to the evaluation of other activities requiring the initial investment of statutory surplus.