Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: The Society of Actuaries are once again offering a seminar that investigates all aspects of life insurance, annuity and long term care product tax compliance. Developed by the Taxation Section, participants will be brought up-to-date on recent Internal Revenue Service (IRS) guidance and learn about the newest tax issues related to product design and administration. Legal, IRS and product development experts will provide vital insights into the challenges of developing and administering products within the requirements of the Internal Revenue Code (IRC), and allow ample opportunities for networking, questions and information exchange.September 12The optional “boot camp” will provide an intense introduction to the basics of product taxation. The boot camp will include sessions focused on life insurance, annuities, and long-term care combination products. The basis of the boot camp will be the authoritative textbooks, “Life Insurance and Modified Endowments Under IRC Sections 7702 and 7702A” and the “Annuities Answer Book.” Book authors will conduct these optional programs. September 13–14The general sessions will feature product, tax, legal and compliance experts as well as Internal Revenue Service (IRS) representatives. Recent changes in the qualification requirements of insurance products and a host of product tax issues beyond Internal Revenue Code (IRC) section 7702 and 7702A will be emphasized.

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.