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: This article discusses the temporary waiver and how it provides only limited relief from the section 401a9 minimum distribution requirements.

Description: This editorial highlights the hot topics happening in the tax industry today.

Description: A discussion of spousal provisions that are governed by federal income tax law, specifically the difference between some state laws and the Defense of Marriage Act DOMA.

Description: A discussion of how the tax law changes of 2003 might affect the attractiveness of variable annuity business relative to mutual funds and direct investments in dividend paying equities.

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.