Description: Congress has acted in recent years to remove outdated provisions governing the federal income taxation of life insurance companies from the Internal Revenue Code. In particular, section 809 and section 815 were repealed and suspended, respectively, in 2004. This article chronicles the demise of these provisions and explains why Congress was right in removing them from the Code.

Description: Full version of Taxing Times, February 2007, Volume 3, Issue No. 1.

Description: Discusses Internal Revenue Service Ruling 2011-9. Since ruling now applies to all taxpayers, not just the taxpayer in a prior private letter ruling, taxpayers that have taken a contrary position in past tax years may need to amend prior tax returns.

Description: The article summarizes several recent private letter rulings from the IRS addressing the "investor control" doctrine in the context of funds of funds.

Description: This article discusses a new procedure for correcting inadvertent failures to satisfy the diversification requirements applicable to variable annuity and life insurance contracts under section 817h of the Internal Revenue Code.

Description: A brief overview of the rules for corporate owned life insurance in section 101j and then summarizes the guidance contained in the IRS notice.

Description: Discusses PLR 201105012, the investor control doctrine, and how the IRS concluded that shares of a Lifecycle Fund, available only through a life insurance company's separate account, still can be considered owned by the insurer and not the policyowner for federal income tax purposes even if it at least partly invests in shares of public funds.

Description: This article begins with an overview of how the tax treatment of partial exchanges has evolved over the last decade or so, including the concerns that led the Service to resist giving taxpayers carte blanche on such transactions.The new guidance shortens from 12 to six months the window following a partial exchange in which the transaction could be called into question, and simplifies the regime by de-linking it from the exceptions to the section 72q penalty tax.4 Finally, the guidance provides coordination with recent partial annuitization legislation and answers to other open issues. This article then summarizes Rev. Proc. 2011-38 and elaborates on why the features outlined above are important and helpful improvements over prior guidance.

Description: Discussions on: 1. tax deductability of surrender losses of life insurance contracts 2. the IRS questioning of the immediate drop in asset values for variable product valuations 3. the analysis of risk distribution in the context of reinsurance and 4. Life Company Net Operating Loss NOL Carryback.

Description: Description * This article summarizes Rev. Proc. 2018-54, in which the IRS provides for a new elective procedure that is intended to help segregated asset accounts and insurance-dedicated funds comply with the diversification requirements of Code section 817(h) with respect to investments in a new type of security known as a Uniform Mortgage-Backed Security.