Description: Company Tax Issues

Description: The article discusses a recent IRS private ruling on the application of the investor control doctrine to a variable contract for which the insurer proposed to add a new investment option. The new option closely paralleled a mutual fund that was open to public investment, i.e., it appeared to be a "clone," but the new option was itself not available outside of the variable contract. The IRS ruled that the doctrine did not apply.

Description: Primer on the federal income taxation of nonqualified annuities

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: 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: 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: 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: Provides information on Section 7702 mortality requirements, the implications of the adoption of the 2017 CSO tables and the need for IRS guidance.

Description: The articles describes Revenue Procedure 2018-20, providing historical background as well as discussing the content of the new procedure.

Description: The article summarizes the new net investment income tax proposed regulations recently published by the IRS as they relate to life insurance and annuity contracts.