Description: This article provides an alternative method to the computation of the Reduction in Benefits Test under 7702A. Part 1 provided for reduction in death benefits. Part 2 provides for reduction in Qualified Additional Benefits.

Description: Discussion of recent developments in the taxation of noncoordinated benefits such as fixed indemnity, hospital indemnity, and specified disease insurance policies. Developments include a recent Chief Counsel Advice Memorandum and proposed triagency rulemaking that would impact non coordinated benefits.

Description: Enacted pursuant to the 2017 Tax Cuts and Jobs Act (TCJA) , the base erosion and anti-abuse tax (BEAT) is one of the most dramatic changes to the U.S. international tax landscape in recent years. The BEAT is essentially a minimum tax which applies to certain large U.S. and foreign corporations with U.S. operations with average annual gross receipts of at least $500 million and a base erosion percentage of 3 percent or higher (with some exceptions).

Description: IRS published final regulations on updated life expectancy and distribution period tables used for determining RMDs. The article intends to provide an overview on the development of the final regulations and highlight the key updates in final regulations, the transition rules to apply final regulations and some of the relevant issues not addressed in final regulations (e.g. MITT, Rev. Rul. 2002-62 and Notice 2004-15). The article also briefly discusses what financial institutions and actuaries would like to do before the regulations become effective on Jan. 1, 2022.

Description: The article focuses on the policyholder tax considerations specific to various types of contracts sold by life insurance companies. When evaluating merger and acquisition or reinsurance transactions, buyers need to be aware of the product tax compliance (PTC) requirements and evaluate any associated risks

Description: This update column from ACLI the “General Explanations of the Administration’s Revenue Proposals for Fiscal Year 2022” (Green Book).