Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: Illustrates the lack of clarity about how the various grandfather clauses applicable to life insurance contracts should be applied in practice.

Description: The recent Tax Technical Corrections Act of 2007, Pub. L. 110-172, signed into law on Dec. 29, 2007, includes a provision that permits a taxpayer to select positions in a straddle and thereby avoid surprise applications of the straddle rules by the IRS on audit.

Description: Two relatively recent developments have heightened tax managers’ anxiety concerning the possible disclosure of tax accrual workpapers.

Description: Comparison of statutory and tax accounting rules in treatment of non-performing assets.

Description: This article highlights the achievements and successes of the section in 2008.

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

Description: This editorial highlights the hot topics happening in the tax industry today.

Description: Discussions on: 1. tax deductability of surrender losses of life insurance contracts 2. the IRS questioning of the immediate drop in asset values for variable product valuations 3. the analysis of risk distribution in the context of reinsurance and 4. Life Company Net Operating Loss NOL Carryback.

Description: A discussion of spousal provisions that are governed by federal income tax law, specifically the difference between some state laws and the Defense of Marriage Act DOMA.