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Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

Description: This is an article about final tax regulations issued in April which provide helpful guidance on the acquisition of insurance companies pursuant to an election under section 338 of the Internal Revenue Code and assumption reinsurance of blocks of insurance when accompanied by the acquisition of other business assets.

Description: This letter discusses answers to the question “Is Homogeneity Required to Qualify as Insurance?”

Description: This article is a discussion of the proposal to tax the inside build-up in life insurance policies and the consequences if it were to be adopted.

Description: Un-MECing a MEC by Arthur C. Schneider & Cherri R. Divin from The Financial Reporter, October 1999, Issue No. 40.

Description: Federal Tax Issues Under the 2001 CSO Mortality Tables

Description: Overview of articles in the October 2013 issue of TAXING TIMES.

Description: This article illustrates how today’s retirement system tools have potential to achieve financially secure retirement and lists options for system improvement.

Description: This article provides a high-level description of how the One Big Beautiful Bill passed enacted on July 4, 2025 specifically affects life insurers. Primarily in this article, ACLI reflects on its 18-year collaboration with the Society of Actuaries through the Taxing Times publication, highlighting key tax legislation impacts and ongoing advocacy for the life insurance industry. This final column acknowledges past achievements and emphasizes continued commitment to industry representation amid evolving challenges.