Description: Tax considerations in structuring and pricing long-term care transactions. Includes consideration around the form of reinsurance and the unified loss rules applicable to stock transactions where they is a bargain purchase (also known as a tax basis step-down)

Description: This article provides a basic introduction to the taxation of qualified annuities held in qualified retirement plans and IRAs. The article has been updated for the SECURE Act and the SECURE 2.0 Act. The article describes the basic types of employer-based plans, provides of overview of the taxation of contributions and benefits when annuities are held in connection with plans and IRAs, explains the required minimum distribution rules, and offers a brief introduction to recent legislation impacting qualified annuities.

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: This article, another in the popular series devoted to tax basics, provides an overview of how the Employee Retirement Income Security Act of 1974 (ERISA), the law governing employment-based retirement and health plans, impacts the use of annuities in pension and 401(k) plans. The article explains which types of plans are subject to ERISA, and which are not; why the concept of "plan assets" is critical; what duties an insurance company or distributor might take on when an annuity is placed with a retirement plan; and finally what disclosures may be required. The article also includes a brief introduction to terminal funding annuities. This article is intended for those with no prior experience in ERISA. Because the vast majority of retirement assets are saved originally in employment based plans like pension and 401(k) plans, understanding the basics of ERISA is important for anyone who will have a career in annuities and life insurance.

Description: Tax code tidbits

Description: Taxing Times -- Volume 11, Issue 2, June 2015

Description: Overview of upcoming second edition of book.

Description: A discussion of the effective dates and statutory reserves cap for variable annuities under Actuarial Guideline 43.

Description: Summary of Administration's FY 2023 Tax Proposals of Interest to Life Insurers

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.