Description: A discussion of how issuers and providers of IRAs and employer-provided qualified retirement plans need to consider all situations and possibly modify their administrative systems and/or procedures for purposes of administering the IRAs and plans in accordance with the RMD required minimum distribution rules.

Description: Last March, Congress passed and the President signed the Patient Protection and Affordable Care Act followed by the Health Care and Education Reconciliation Act, which amended the former collectively, the “Act”. The article provides a brief background on the passage of the Act generally and the creation of the new Investment Income Tax in particular compares the existing provisions of the HI tax with the newly enacted provisions, and it then analyzes the import of the Investment Income Tax for annuities and, possibly, life insurance contracts. The article concludes with thoughts on the potential effect of the new tax on the annuity marketplace.

Description: Discusses PLR 201046008, regarding addition of a rider to a variable life policy that provides a minimum annual amount of withdrawal or policy loan. Includes discussion of impact on NSP under CVAT, and Guideline Premium.

Description: The article provides an introduction to tax accounting for U.S. life insurance companies, with a focus on NAIC statutory accounting concepts. The author discusses permanent and temporary differences, the current tax provision, and deferred tax accounting requirements, including admissibility testing under SSAP No. 101.

Description: The article discusses two IRS private letter rulings addressing the application of the section 72(s) after death distribution requirements to joint-life GLWBs covering non-spouses. The article explores the legal basis for the IRS conclusion and the potential utility of the distribution method approved by the ruling.

Description: Overview of upcoming second edition of book.

Description: Introductory column written for each issue, expressing the views of the Section's Chairperson

Description: October issue of Taxing Times

Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

Description: Examines Notice 2016-39 on phased retirement payments from defined benefit plans and its inapplicability to non-qualified annuities under Rev. Proc. 2016-36