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

Description: Updates on partial annuitization and exhanges, prevailing CSO valuation mortality tables, disclosure of offshore accounts through FATCA.

Description: A discussion of substantially equal periodic payments, SEPPs, and the penalty tax that is associated with SEPPs, the Recapture Rule. Computation methods are also discussed.

Description: This article discusses the temporary waiver and how it provides only limited relief from the section 401a9 minimum distribution requirements.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.