Description: The interaction of section 7702 cash value accumulation test [CVAT] and state nonforfeiture laws [SNFL] create a dual limitation on traditional life insurance contratcs. CVAT limiting the maximum permissible cash value and SNFL requiring a minimum cash surrender value. This article examines these dual limitations.

Description: October issue of Taxing Times

Description: The actuarial committee that authored this report developed a model to estimate the revenue the tax would generate. The results point out key considerations for an excise tax on high cost health plans, including the wide range of results generated by sensitivity to certain assumptions.

Description: The U.S. Technical and Miscellaneous Revenue Act of 1988 has created a very significant administrative problem for companies having a large block of “grandfathered” universal life business. The problem is that seemingly harmless future changes in benefits are categorized as “material changes,” causing a policy to lose its grandfather status and subjecting it to the “modified endowment” rules.

Description: The author uses a reprint of an article from the very first edition of the “News from the Individual Life Insurance and Annuity Product Development Section” and assistance from the Taxation Section Council and Friends of that Council to decipher the changes between the life insurance tax environment back in the 1980s compared to today.

Description: Update on industry action on legislative and tax regulatory items affecting the life insurance industry.

Description: Small Talk Newsletter, June 2005, Issue No. 24. Last fall, the Internal Revenue Service IRS released Notice 2004-61, 2004-41 I.R.B. 596 October 12, 2004, interpreting the reasonable mortality charge requirement applicable to life insurance contracts under Section 7702 of the Internal Revenue Code.

Description: This article details the IRS' Revenue Ruling 2005-6. This ruling provides formal guidance on how to treat family term riders for purposes of the computational limit calculations in Internal Revenue Code IRC sections 7702 and 7702A i.e., calculations of net single premiums, guideline single premiums, guideline level premiums and 7-pay premiums. From Small Talk Newsletter, June 2005, Issue No. 24.

Description: This paper discusses the following cases: Rudolph V. United States- concerning taxability of agent convention travel, State Board Insurance v. Todd Shipyards Corporation- concerning premium tax for unlicensed insurers, United Services Life Insurance Company v. Delaney- concerning aviation restrictions in a life insurance policy, Metropolitan Life Insurance Company v. Wood- concerning conditional approval, Hartford Live Stock Insurance Company v. Phillips- concerning livestock insurance with an undisclosed pre-existing condition, State Security Life Insurance Company v. Kinter- concerning the due date for monthly premiums to prevent lapsation.

Description: On May 24, 2005, the Treasury Department and Internal Revenue Service published a notice of proposed rulemaking the “Notice” proposing regulations under Internal Revenue Code §7702, the federal tax definition of a “life insurance contract.” Discussion of determining 'attained age' for joint or multiple life policies.