Description: This article is a companion to “They Go Bump in the Night: Life Insurance Policies and the Law of Material Change,” an article written by John T. Adney and Craig R. Springfield (May 2012 Taxing Times Supplement) that describes the various material change rules found in the Code, highlighting the complexities insurers face in navigating through these rules when a life insurance contract is materially changed. The Adney and Springfield article also addresses the difficulties in interpreting the tax law requirements under the various effective date rules contained in the Code sections affecting life insurance contracts.

Description: This article discusses Internal Revue Code, ‘IRC,’ Sections 7702 and 7702A with respect to the implementation of the 2001 CSO Mortality Table, which must be used in the calculations for policies issued on or after January 1, 2006. “The insurance industry has requested guidance from the Treasury Department and the Internal Revenue Service on the proper application of the current computational rules to the 2001 CSO Mortality Table but, to date, such guidance has not been provided. Therefore, the Taxation Section established the 2001 CSO Maturity Age Task Force, the members of which authored this article, to propose methodologies that would be actuarially acceptable under Sections 7702 and 7702A of the Code for calculations under contracts that do not provide for actual maturity before age 100.” This article summarizes the task force recommendations.

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: Discussion of the March 1, 2013 Internal Revenue Service (“IRS”) release of PLR 201309011, which addresses the application of the section 817(h) diversification requirements to variable contracts that have invested in illiquid investment vehicles (the “Funds”).

Description: The article describes changes to the computation of tax reserves as a result of the Tax Cuts and Jobs Act.

Description: Recent guidance in the form of Rev. Proc. 2006- 13 provides a general safe harbor for the fair market value of a deferred-annuity contract when determining the amount includible in income on conversion of a traditional IRA to a Roth IRA.

Description: Changes to AG 43 and what that might mean for tax purposes. Also, summary of IRS Notice 2016-63 (provides safe harbor tax guidance on use of 2017 CSO tables).

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: The article describes changes to the computation of discounted unpaid losses (claim reserves) as a result of the 2017 tax legislation.

Description: This article is an introduction to the principles of taxation of U.S. owned foreign insurance operations, such as controlled foreign corporations.