Description: A discussion of Section 7702 and age 100 insured and the need for guidance on combined annuity and long-term care contracts

Description: This article discusses several issues related to the IRS and taxation. These include partial exchanges of non-qualified annuity contracts, Long Term Care features on Annuity or Life contracts, and the applicability of the Foreign Account Tax Compliance Act [FATCA] to Life Insurance Campanies and products.

Description: A discussion about the taxation of life insurance companies and affiliated products and the ramifications it has annuity contracts and long-term care.

Description: On Aug. 11, 2011, the Internal Revenue Service IRS released Notice 2011-68,1 regarding the tax treatment of stand-alone and “combination” longtermcare LTC insurance products. The Notice provides interim guidance on certain issues and requests public comment on others. This article discusses that notice and taxation issues related to Long Term Care products, combination products and long term care riders to annuities.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: Discussion of recent developments in the taxation of noncoordinated benefits such as fixed indemnity, hospital indemnity, and specified disease insurance policies. Developments include a recent Chief Counsel Advice Memorandum and proposed triagency rulemaking that would impact non coordinated benefits.

Description: Article from The Actuary, December 1986 – Volume No. 20, Issue No. 10 that talks about The Tax Reform Act of 1986.

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.

Description: October issue of Taxing Times