Description: The article summarizes the provisions of H.R. 1 that impact the tax qualification of life insurance contracts and the tax reporting of life settlements

Description: Notice 2004-611 is the latest in a series of administrative pronouncements from the Internal Revenue Service related to the appropriate mortality assumptions to be used in computing the definitional limitations under Internal Revenue Code Section 7702 and the seven-pay limitation under the Section 7702A modified endowment rules.

Description: One of the significant tax benefits of a life insurance contract is that, for purposes of determining the taxable amount of proceeds received under the contract on distributions or surrender,the investment in the contract includes the aggregate amount of premiums, unreduced by the cost of insurance provided IRC section 72c. IRS rules net surrender value reserves must be reduced by a YRT reserve credit.

Description: Legislation imposing new restrictions on a wide range of compensation arrangements was signed into law on October 22, 2004. The American Jobs Creation ActAJCA adds a new section 409A to the Internal Revenue Code, which imposes restrictions on funding, distributions, and elections to participate in nonqualified deferred compensation plans.

Description: Articles on IRS private letter rulings on combination products, IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702.

Description: This article discusses the the 1998 alternartive XXX model regulations and the potential tax impact on the definition of life insurance and on reserve deductions associated therewith.

Description: This article addresses the 2001 CSO Mortality Table and the implications for preneed insurance, for which the table has been deemed inadequate. The article explores interim measures such as additional reserves, treatment as substandard, and tax implications. There is also discussion of a model NAIC regulation which would mandate the use of 1980 CSO mortality for preneed as well as efforts to eventually establish a new preneed mortality table for valuation and nonforfeiture purposes.

Description: The Required Minimum Distribution [RMD] Working Group of the SOA Taxation Section has completed research identifying considerations for actuaries and annuity insurers in determing the actuarial present value of additional benefits for computing the RMD under a deferred annuity contract. This is the Appendix I spreadsheet for determining the Actuarial Present Value of an annuitization bonus. Please see the SOA website research for the full report and other associated spreadsheets.

Description: This article outlines the IRS directive published in July 2014, which provides a safe harbor treatment for variable annuity hedging gains and losses relating to VA contracts issued before Dec. 31, 2009.

Description: Issues covered in this article include 1. Tax treatment of advance interest on policy loans, 2. Tax treatment of Credit default swaps, 3 Application of SRLY [Separate Return Limitation Year] Cumulative Register Concept to Dual Consolidated Losses, and 4. FATCA [Foreign Account Tax Compliance Act] Transitional Relief.