Description: This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment company, (2) the deductibility of interest expenses by the LLC and its members, and (3) the excludability of death benefits under the Policies, which began life as employer-owned life insurance contracts.

Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: Summary of private letter ruling the IRS released in February 2013 regarding a partnership formed to hold and manage bank-owned life insurance contracts. The article follows up another article from the same authors in the May 2012 issue of Taxing Times regarding an earlier ruling on a similar structure.

Description: Discusses earlier IRS rulings on Contingent Deferred Annuities and the latest ones, PLRs 201117012 and 201117013. Highlights two important additional issues covered in latest rulings.

Description: The article discussing the differing tax definitions of life insurance in the US and Canada and relates them to new international tax reporting regimes such as FATCA.

Description: The article discusses a recent IRS private letter ruling granting IRC section 72(b) exclusion ratio treatment for amounts received from an innovative payout option.under a deferred variable annuity.

Description: Overview of upcoming second edition of book.

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

Description: Basic discussion of premiums paid, investment in the contract, and basis as used in IRC provisions applicable to life insurance and annuity contracts.