Description: On January 19, 2005, the Treasury Department and the Internal Revenue Service the “Service” responded to a life insurance industry request for guidance on the treatment of qualified additional benefits “QABs” under sections 7702 and 7702A of the Internal Revenue Code through the release of Revenue Ruling 2005-6 the “Ruling”.

Description: COLI products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest. This COLI Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides an analysis of the Sixth Circuit reversal of a trial court decision in a case involving economic substance.

Description: Almost 65 years ago, the Supreme Court issued its opinion in Helvering v. Le Gierse, addressing when an arrangement should be recognized as involving “insurance” for federal income tax purposes. According to the Court, an “insurance risk” must be present, and for an insurance risk to exist, there must be “risk-shifting and risk distribution.”

Description: Recognition of out-going and incoming council membership.

Description: How including the intent and rationale of the tax law in system specifications can lead to better software system designs.

Description: This article describes the transfer pricing rules applicable to life reinsurance transactions generally, and then outlines a methodology for testing life reinsurance transactions to demonstrate compliance with transfer pricing standards applied by tax authorities.