Description: Tax considerations in structuring and pricing long-term care transactions. Includes consideration around the form of reinsurance and the unified loss rules applicable to stock transactions where they is a bargain purchase (also known as a tax basis step-down)

Description: This article discusses the Section 338h10 election on the disposition of an insurance company.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: Taxing Times -- Volume 11, Issue 2, June 2015

Description: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

Description: This article considers PLR 201304003, which addressed the application of Internal Revenue Code section 1035 to the exchange of a survivorship, or “second-to-die,” life insurance contract after the death of one of the insureds for a new life insurance contract covering only the life of the surviving insured.

Description: Update on Life Insurer Legislative and Regulatory issues

Description: On June 17, 2019, the Internal Revenue Service published Final Regulations implementing changes to loss reserve discounting under section 846 of the Internal Revenue Code made by the Tax Cuts and Jobs Act. This note addresses changes made in the Final Regulations, particularly modification of rules for determining the interest rate used for discounting, in response to comments from taxpayers on the proposed regulations.

Description: This article summarizes the treatment of changes in the basis for determining life insurance tax reserves under prior law and describes the changes enacted by the Tax Cuts and Jobs Act. It further explains the procedures for changing the basis of computing reserves under the new rules as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses the uncertainties that remain.

Description: Description * This article summarizes Rev. Proc. 2018-54, in which the IRS provides for a new elective procedure that is intended to help segregated asset accounts and insurance-dedicated funds comply with the diversification requirements of Code section 817(h) with respect to investments in a new type of security known as a Uniform Mortgage-Backed Security.