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: An exploration of drivers, cohorts and dynamics for policyholder behavior for VA and FIA based on industry experience data, including changes in recent years and the emergence of long-term data in key areas. We will also discuss critical elements to developing a sustainable and coherent framework to translate this complex experience data into assumption models.

Description: An overview of the evolution of equity-based guarantees (e.g. VA, FIA, etc.) over the last few years and discussion the current lay of the land as it relates to the regulatory, issues, capital markets environment in which these products are offered.

Description: How to set asset assumption, at the cycle or through the cycle and other considerations