Description: The article discusses the recent final and proposed regulations published by the IRS and Treasury on the required minimum distribution rules for qualified plans, which implement changes made by SECURE 1.0 and SECURE 2.0. The article is intended to identify the important rules in the final regulations, provide a framework for determining how the rules apply to beneficiaries of qualified plans and IRAs, describe the key differences between the earlier 2022 proposed regulations and the final regulations, and it summarizes the SECURE 2.0 provisions contained in the new proposed regulations.

Description: The article analyzes Private Letter Ruling 202031008, which considers how Internal Revenue Code sections 72(q) and (u) apply to an annuity contract issued to a trust. In particular, the Ruling interprets the terms “taxpayer,” “holder” and “held by” in those Code sections in situations where a non-qualified deferred annuity contract is issued to a grantor trust or a non-grantor trust. The Ruling’s analysis and conclusions differ in some respects depending on which of these types of trusts is involved. In addition, although the Ruling does not address sections 72(s) or 72(e)(4)(C), the Ruling has potential implications under those provisions because they also use the term “holder” and “holds,” respectively.

Description: This article discusses new tax reporting requirements for transfers for value under section 6050Y. It also discusses changes to the transfer for value rule of section 101(a)(2) and (3), including the definition of a reportable policy sale.

Description: The article describes recently proposed regulations on the deduction of partially-worthless debts under section 166. It also provides background on the comments submitted by the insurance industry in response to the proposed regulations and additional guidance issued by Treasury and the IRS following the publication of the proposed regulations.

Description: The article introduces two previously published articles.

Description: This article provides a basic introduction to the taxation of qualified annuities held in qualified retirement plans and IRAs. The article has been updated for the SECURE Act and the SECURE 2.0 Act. The article describes the basic types of employer-based plans, provides of overview of the taxation of contributions and benefits when annuities are held in connection with plans and IRAs, explains the required minimum distribution rules, and offers a brief introduction to recent legislation impacting qualified annuities.

Description: This article discusses final Treasury Regulations published in October 2019 under Internal Revenue Code sections 101 and 6050Y. The regulations cover new tax reporting requirements for transfers and sales of life insurance contracts, as well as changes to the transfer-for-value rules related to reportable policy sales

Description: This article provides an overview of the Regs and highlights important open issues regarding determination of a U.S. shareholder’s GILTI amounts.

Description: This article provides a high-level description of how the One Big Beautiful Bill passed enacted on July 4, 2025 specifically affects life insurers. Primarily in this article, ACLI reflects on its 18-year collaboration with the Society of Actuaries through the Taxing Times publication, highlighting key tax legislation impacts and ongoing advocacy for the life insurance industry. This final column acknowledges past achievements and emphasizes continued commitment to industry representation amid evolving challenges.

Description: The article provides an introduction to some of the key limitations that the Internal Revenue Code imposes on business uses of life insurance, focusing on the limitations under Section 264(a) on business deductions for premiums and interest expenses related to life insurance, the similar limitations under Section 264(f) for unrelated interest expenses of businesses that own life insurance, the limitations under Section 101(j) on the excludability of death benefits under employer-owned life insurance contracts, and the recently-enacted rules for life settlement transactions.