Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: This article reviews the definition of “cash surrender value” in section 7702f2A and in the regulations proposed under that provision but never finalized. The discussion then recaps the 2005 Rulings and describes the recently issued letter rulings.

Description: A discussion of the proposed safe harbor with respect to calculations for contracts where the insured reaches age 100.

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: 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: The article discusses ACLI's comment letters submitted to Treasury and the IRS in response to the proposed regulations on the Corporate Alternative Minimum Tax and Ranking Member Ron Wyden (D-OR)'s discussion draft of the Protecting Proper Life Insurance From Abuse Act, that would impact the taxation of some to private placement life insurance.

Description: The article discusses court decisions on the tax basis and taxable gain in life insurance contracts.

Description: Description of general tax consequences of purchasing an insurance company, either through buying the assets or buying the stock.

Description: Kory J. Olsen, Taxation Section chair, interviewed Walter Welsh, focusing on the ACLI, retirement issues, and insurance regulation.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.