Description: This article is a general discussion about earnings rates and toll charges and how to compute them.

Description: This article is a general discussion about prior correction procedures for failed life insurance contracts and the new IRS procedure for remediation.

Description: Tax code tidbits

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: This article begins with a brief review of the general requirements of section 7702A and the consequences of MEC status for a life insurance contract and continues with a description of the evolution of the inadvertent MEC correction procedures over the past near decade.

Description: A comprehensive look at Actuarial Guideline 43 VA CARVM. This article examines the statutory and tax implications of AG 43 for the determination of reserves for annuity writers.

Description: The article discusses recently-issued regulations under section 807 of the Internal Revenue Code, concerning the computation and reporting of reserves. The provisions addressed generally relate to the Tax Cuts and Jobs Act of 2017.

Description: This article outlines how Bermuda advanced in global tax compliance through the enactment of the Bermuda Corporate Income Tax (CIT) Act of 2023, which will take effect for tax years beginning on or after January 1, 2025. The Bermuda CIT rules incorporate key foundational definitions from the Organization for Economic Cooperation and Development’s (OECD) Pillar Two GloBE model rules, while also exhibiting significant differences from Pillar Two. The article discusses the various elections available for taxpayers, key mechanics of the CIT, and the latest administrative guidance released by the Government of Bermuda.

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.