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: Many life insurance companies that issue participating policies follow business practices that they argue allow them a deduction for tax purposes for policyholder dividends in the year prior to actual payment. This article discusses several recent developments related to policyholder dividend accruals, including Revenue Ruling 2011-29 and the New York Life and MassMutual cases, and highlights the four arguments commonly made by the IRS in challenging companies' claimed tax treatment of such dividends.

Description: On Nov. 2, 2018, the Internal Revenue Service (IRS) released Technical Advice Memorandum 201844009 (the TAM).

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: Update on industry action on legislative and tax regulatory items affecting the life insurance industry.

Description: The traditional defined-benefit (DB) plan is a type of plan structured to provide the greatest degree of retirement income security, designed to pay out a guaranteed retirement income for the life of the retiree (and, when applicable, a beneficiary). However, over the last several decades, the number of private-sector employees covered under these traditional plans has decreased dramatically and been replaced by defined contribution (DC) plans. In contrast, public-sector retirement plans, which are exempt from ERISA, have seen a much smaller decline in DB plans. There are many differences in the private and public sector that likely contributed to this phenomenon, but ERISA and the many amendments to it has been a major factor.

Description: Read the February 2017 issue of Taxing Times published by the The Taxation Section. Newsletters provide practical information for the working actuary, articles on trends that impact sections and news about section activities.

Description: Highlights of recent activities of the Taxation Section

Description: Updated discussion of IRS Proposed Regulations under Section 162(m)(6), their potential impact upon the life insurance industry, and a 2 percent de minimis exception.

Description: Over the past few years, the Internal Revenue Service has issued two private letter rulings waiving the failure of certain fixed-premium universal life insurance FPUL contracts to satisfy the guideline premium test GPT under section 7702 of the Internal Revenue Code [see PLR 200328027 Apr. 10, 2003 and PLR 200230037 Apr. 30, 2002].