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 growing aging population presents unique challenges and opportunities, especially for the financial services industry. Presenters will explore the issues with particular focus on demographic challenges, such as age dependency ratios and implications for sovereign debt and public policy. They will also compare and contrast private sector offerings across the globe. In particular, as an example of a super-aging society, presenters will describe how Japanese insurers and pension funds tackle longevity risk.