Description: When a life insurance company changes its basis for computing tax reserves, a special 10-year spread rule found in section 807(f) of the Internal Revenue Code applies to the change. But, what happens if the statutory accounting for original issue discount (OID) or bond premium changes? A discussion follows.

Description: A discussion of risk and tax risk.

Description: The article discusses two IRS private letter rulings addressing the application of the section 72(s) after death distribution requirements to joint-life GLWBs covering non-spouses. The article explores the legal basis for the IRS conclusion and the potential utility of the distribution method approved by the ruling.

Description: Overview of upcoming second edition of book.

Description: Introductory column written for each issue, expressing the views of the Section's Chairperson

Description: October issue of Taxing Times

Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

Description: Examines Notice 2016-39 on phased retirement payments from defined benefit plans and its inapplicability to non-qualified annuities under Rev. Proc. 2016-36

Description: Chairperson's column for the October 2020 issue of Taxing Times with thoughts on the effects of COVID-19 on the Taxation Section.

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.