Description: Full version of Taxing Times, May 2007, Volume 3, Issue No. 2.

Description: Examines the Treasury Department and IRS guidance in determining whether a financial arrangement qualifies as insurance under federal tax law. It concerns the concepts of fortuity, homogeneity, and risk distribution, among others.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.

Description: On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine in Webber v. Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets supporting a variable life insurance contract purchased through a private placement transaction. In the end, however, the Webber court leaves a lot of questions unanswered—most significantly, the elusive answer to how to define investor control. This article examines the Investor Control Doctrine, as explained and applied by the U.S. Tax Court in Webber, and considers some of the open questions that remain after June 30, 2015.

Description: Full version of Taxing Times, February 2007, Volume 3, Issue No. 1.

Description: Discusses proposed regulations regarding reserve deductions for certain captives under IRC Section 1502 related to consolidated group intercompany insurance transactions.

Description: This article is a discussion about the life settlement industry and the tax considerations for life insurance bought and sold in the secondary market.

Description: A discussion of new IRS rulings with respect to the taxation of life settlement transactions.

Description: Discusses the IASB insurance contract project and the major components of the new accounting standard, including the guidance it provides regarding how to define the term “insurance contract.”

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.