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: This article discusses how new and current industry tax topcs can educate the Taxation Section membership.

Description: This article provides a short history of the correction procedures previously developed to address compliance failures and the shortcomings of those procedures under sections 101f and 7702, laying the foundation for a sea change in the correction process.

Description: This article discusses tax rates used in computing toll charges for closing agreements with respect to corrections under IRS section 7702.

Description: The IRS believes that any segregated asset account comprised of a pool of individual securities will run afoul of the investor control doctrine. This article articulates that such a conclusion would be deeply flawed based on the administrative, congressional, and judicial precedents involving the investor control doctrine.

Description: A discussion of the PLR that addresses a Wellness Rider that an affiliated group of life insurance companies proposed to offer only on a prospective basis with newly issued life insurance contracts.

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: A discussion of: the value of a life insurance contract distributed from a qualified pension plan, IRS industry director directive on the DRD for life insurance separate accounts and IRS actuaries raising new issues on AG 34 tax reserves.

Description: Clarification of the tax treatment of non-qualified deferred annuities that are “partially annuitized” is discussed in detail in this article.

Description: Read the June 2020 issue of Taxing Times published by the Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.