Description: This article discusses final Treasury Regulations published in October 2019 under Internal Revenue Code sections 101 and 6050Y. The regulations cover new tax reporting requirements for transfers and sales of life insurance contracts, as well as changes to the transfer-for-value rules related to reportable policy sales

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: Read the June 2020 issue of Taxing Times published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.