Description: This article discusses the self-certification procedure for late rollover contributions established by the IRS in Revenue Procedure 2016-47.

Description: The article summarizes several recent private letter rulings from the IRS addressing the "investor control" doctrine in the context of funds of funds.

Description: The Taxing Times editor discusses what is in the current issue as well as Obama adminstration tax proposals affecting the insurance industry such as notification requirements and COLI. Also mentioned are IRS expected guidance on deficiency reservs and 7702 defining cash surrender value.

Description: The Chairperson of the Taxation Section shares the section council's plans and goals for 2017

Description: Recognition of out-going and incoming council membership.

Description: Actuary/accountant/tax attorney dialogue on recent guidance issued regarding treatment of deficiency reserves with respect to the “statutory reserves cap” of Internal Revenue Code section 807(d)(1).

Description: At the beginning of this year, Representative Dave Camp (R-MI) retired from the House of Representatives after 12 terms, the last two terms serving as Chairman of the Committee on Ways and Means. Chairman Camp has played a central role in the national conversation on tax reform, primarily through a series of discussion drafts addressing international tax reform, financial products tax reform, small business tax reform and, most recently, a comprehensive tax reform discussion draft that we explored in a special edition of TAXING TIMES last fall. Kristin Norberg, TAXING TIMES editor, recently sat down with Chairman Camp to talk about his career in the House, the development of the Tax Reform Act of 2014, and some of its potential impacts on the insurance industry.

Description: Almost 65 years ago, the Supreme Court issued its opinion in Helvering v. Le Gierse, addressing when an arrangement should be recognized as involving “insurance” for federal income tax purposes. According to the Court, an “insurance risk” must be present, and for an insurance risk to exist, there must be “risk-shifting and risk distribution.”

Description: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

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.