Description: The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable mortality requirements

Description: Guidance and interpretation regarding reasonable mortality charge requirement of Section 7702, based from IRS Notice 2004-61, 2004-41 I.R.B. 596 of October 12, 2004.

Description: Discussion of private letter tax rulings on the definition of Cash Surrender Value for purposes of interpreting the definition of life insurance for the policyholder's taxation of the contracts.

Description: This article explores the complexities and potential problems with respect to tax reserves that could result from a retroactive application of a principle-based reserves PBR approach for life insurance reserves.

Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.

Description: In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict liability penalties of 20 percent for understated taxes and refund claims that result from transactions that lack economic substance. In July 2011, the commissioner of the Large Businessand International Division LB&I of the IRS evidently recognized this state of uncertainty and issued very helpful guidance to all LB&I examiners to fill the void on guidance for economic substance..

Description: 1994 SOA Meeting, San Antonio. This session gave Internal Revenue Service and the Treasury Department an opportunity to address specific issues of their choice. Topics included: 1. Nondiscrimination regulations under 401a17. 2. Separate line of business regulations. 3. IRS determination letter. 4. Examination program. 5. Modifications recently made to help plan sponsors cope with the myriad of rules and regulations for which they have to amend their plans.

Description: Presented at October 1996 Annual Meeting. Accruals in nonqualified retirement plans have become subject to FICA taxation. In this session, IRS rules are discussed in detail with emphasis on options available for good faith years through 1996 and final regulation years starting in 1997.

Description: In session 75 PD of the New York Annual Meeting panelists explore practical considerations of maintaining compliance with federal income tax definition of life insurance rules. From the Record of the Society of Actuaries, Vol. 24, No. 3.

Description: Presented at June 1986 Spring Meeting. This session discussion is about the personal financial planning process, including a discussion of the effects of any recent and proposed legislation on individuals.