Taxes

  • Pete Stark
  • transfer-for-value rule of section 101(a)(2)
  • 1983 0311 - GOV - Taxation of Financial Services Industry - [PDF-356p, No Video]

My purpose is to:

  • look at some of the trends in taxation of the life insurance industry and its products,
  • describe the current TEFRA tax environment and its potential impact on product pricing and development, and
  • then to look ahead to what might be expected after TEFRA.

-- WILLIAM R. BRITTON, JR.

1983 - INDIVIDUAL LIFE INSURANCE, Society of Actuaries

1981 GAO Billions of Dollars Are Involved in Taxation of the Life Insurance Industry--Some Corrections in the Law Are Needed 242p
1982 GAO Modified Coinsurance Used to Reduce Taxes 9 pages
1982 JCT General Explanation of the Revenue Provisions TEFRA jcs-38-82 
1983 JCT COMPARISON OF PRESENT LAW, A DISCUSSION PROPOSAL AND POSSIBLE CLARIFICATIONS....relating to the tax treatment of life insurance companies and their products
1984 GOV Tax Treatment of Life Insurance Products and Policyholders HRG98-790

WORDS and CONCEPTS
818(C), ModCo, Guideline Level Premium, Guideline Single Premium, MEC, TEFRA, DEFRA, CVAT, GPT, 7702, 101, Corridor, Inside Buildup

Resources
Life Insurance and Modified Endowments Under Internal Revenue Code Sections 7702 and 7702A, Second Edition -Chris DesRochers, John T. Adney, Brian King and Craig Springfield. 2015

§7702. Life insurance contract defined https://uscode.house.gov/view.xhtml?path=/prelim@title26/subtitleF/chapter79&edition=prelim

  • On November 1, 2005, The President's Advisory Panel on Federal Tax Reform ("Panel") submitted its report ("Report") to the Secretary of the Treasury.1
  • At 272 pages, this is the most important and wide-ranging plan to reform the United States federal tax system since Blueprints for Basic Tax Reform (1977).2

2006 - AP -The Report of the President's Advisory Panel on Federal Tax Reform: A Critical Assessment and a Proposal, Reuven S. Avi-Yonah

  • The Save for Retirement accounts would replace existing IRAs, Roth IRAs, Nondeductible IRAs, deferred executive compensation plans, and tax-free “inside buildup” of the cash value of life insurance and annuities.
  • Contributions would be made with after-tax dollars like current law Roth IRAs and earnings would grow taxfree.

https://www.treasury.gov/resource-center/tax-policy/documents/report-fix-tax-system-2005.pdf