Description: A statement about the article peer-review process for the newsletter, and a disclaimer about interpreting any article content as tax, legal, or other advice.

Description: The Internal Revenue Service issued its seminal ruling interpreting Internal Revenal Code section 7702A[c][3][B][i], commonly referred to as the Necessary Premium Test [NPT]. The purpose of the NPT is to shelter certain death benefit increases from material change status, avoiding the 7 pay test's reapplication on their account.

Description: For actuarial projections to serve as the management tools that they are intended to be, the persons charged with making those projections need to consider whether the projection is sufficiently sophisticated so that it does not miss major items.It is important to consider the tax effect. This article covers several of the major tax issues that should be considered in any actuarial projection.

Description: May 2012 Taxing Times - the May 2012 issue of Taxing Times, the newsletter of the Taxation Section

Description: A diverse variety of topics covering developments in the taxation of life insurance products and companies is highlighted. Two articles in the accompanying May supplement, which relate to the concept of material changes under the tax law, are also mentioned.

Description: Many life insurance companies that issue participating policies follow business practices that they argue allow them a deduction for tax purposes for policyholder dividends in the year prior to actual payment. This article discusses several recent developments related to policyholder dividend accruals, including Revenue Ruling 2011-29 and the New York Life and MassMutual cases, and highlights the four arguments commonly made by the IRS in challenging companies' claimed tax treatment of such dividends.

Description: The different broad purposes served by the material change concept under federal tax law are outlined. More specific material change and similar issues that are pertinent to particular Code provisions and guidance from the IRS that has addressed those issues are also addressed. In the final part of this article, authors comment on whether any overarching principles can be gleaned that can assist insurers and policy owners in making decisions about whether particular changes can safely be made, and thoughts are offered with respect to future potential IRS guidance that would be helpful as taxpayers navigate these often uncertain waters.

Description: A short introduction to the articles in the May 2012 supplement, "They Go Bump in the Night: Life Insurance Policies and the Law of Material Change" and "Administration of the Material Change Rules: Meeting the Challenge."

Description: Article examines a proposed amendment to the MAP-21 Act that would have changed a number of tax requirements regarding so-called life settlements.

Description: A discussion of third-party summons, particularly those issued in promoter examinations. Satisfaction of the IRS's request for information outside of court in the most cost-effective manner is usually the best course.