Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: This article discusses several issues related to the IRS and taxation. These include partial exchanges of non-qualified annuity contracts, Long Term Care features on Annuity or Life contracts, and the applicability of the Foreign Account Tax Compliance Act [FATCA] to Life Insurance Campanies and products.

Description: An update from the ACLI staff to keep readers informed about the organization's work on tax issues affecting the life insurance industry.

Description: Read the latest ACLI Update.

Description: We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of tax reserves computed precisely according to the requirements of the Internal Revenue Code, and the IRS has challenged the reserve deduction. Other sections of this article also cover IRS rulings on the treatment and valuation of an insurance company stock purchased as an asset acquisition and COLI life insurance.

Description: Tells what occurred after the adverse private letter ruling PLR 200738016 up to the issuance of the revenue procedure, and offers some speculation about the future.

Description: Discusses the federal income tax aspects of reserves for term and secondary-guarantee UL, as regulated by XXX and AXXX.

Description: Draft Pre-Need Model proposed by National Association of Insurance Commissioners, NAIC, is analyzed from tax standpoint of both insurers, through sec. 807, and policyholders, through secs. 7702 and 7702A.

Description: This article begins with a brief review of the general requirements of section 7702A and the consequences of MEC status for a life insurance contract and continues with a description of the evolution of the inadvertent MEC correction procedures over the past near decade.

Description: A discussion about premium deficiency reserves and tax regulations for employer-owned insurance contracts