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.

Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].