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: This article begins with a brief review of the treatment of QAB charges under the Code and the guidance the Internal Revenue Service the “Service” has issued regarding the manner in which taxpayers should account for QAB charges Part I. It then describes Rev. Rul. 2005-6’s three alternatives for addressing improper accounting for QAB charges Part II. It also includes a discussion about an Alternative C closing agreement.

Description: Legislation imposing new restrictions on a wide range of compensation arrangements was signed into law on October 22, 2004. The American Jobs Creation ActAJCA adds a new section 409A to the Internal Revenue Code, which imposes restrictions on funding, distributions, and elections to participate in nonqualified deferred compensation plans.

Description: Discusses Notice 2011-02 as it addresses most, but not all, of the outstanding questions about health-care-insurance entities to which the $500,000 compensation rule applies.

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: This article describes Health Savings Accounts HSAs and the tax and other aspects of these funds.

Description: The article describes recently proposed regulations on the deduction of partially-worthless debts under section 166. It also provides background on the comments submitted by the insurance industry in response to the proposed regulations and additional guidance issued by Treasury and the IRS following the publication of the proposed regulations.

Description: The chair of the Taxation Section Council provides a summary of the section's mission and initiatives for the upcoming year.

Description: Provides information on Section 7702 mortality requirements, the implications of the adoption of the 2017 CSO tables and the need for IRS guidance.

Description: Interplay of §807(f) and the stat cap in §807(d) as there continues to be uncertainty as to whether a change to the stat reserve could be subject to §807(f).