TEFRA

  • What happened under TEFRA? Several things:
    • We lost MODCO 820 forever.
    • We had a deceptively modest reduction in 818(c)2.
    • A lot of the teeth were taken out of reinsurance as a tax planning tool.
    • Universal Life was given legitimacy through 101(f).
  • In terms of Anderson's Taxation Horseman, it is now clearly possible for the industry to provide a competitive rate of interest return to policyholders--at least on new money products. 
  • The matter of the existing portfolio of assets is another question, but at least on new money products, the industry is in the position of being able to offer competitive products.
  • In addition, the 818(c)2 adjustment is available for the first time to many companies.

--  William R. Britton, Jr., Vice President and Principal of the Tillinghast firm

1983 - SOA - Individual Life Insurance, Society of Actuaries - 22p

The first attempt to limit the investment orientation of
a life insurance contract was made in section 101(f), added
by TEFRA, which deals only with "flexible premium life
insurance contracts" such as universal life insurance.

  • Section 101(f), is a temporary measure, designed to allow
    sellers of universal life insurance to compete on a equal
    basis with sellers of more traditional policies while providing some limits on the extent to which universal life could be used as an investment vehicle.

Hence, the precise combination of limitations contained in this statute may not be appropriate for a permanent general definition of life insurance.

  • For example, we believe that it is appropriate to
    examine whether single premium policies and policies which endow at an early age should be treated as life insurance for tax purposes.

Nevertheless, the requirements contained in section 101(f), give some indication of the kinds of tests which might be incorporated into such a definition. (p36)

-  JOHN E. CHAPOTON, ASSISTANT SECRETARY FOR TAX POLICY, DEPARTMENT OF THE TREASURY

1983 0510/11 and 0728 - GOV - Tax treatment of life insurance

  • [PDF-974p, No Video] ->Not on govinfo.org
  • Subcommittee on Select Revenue Measures of the Committee on Ways and Means

MEMBER ROSTER OF STOCK COMPANY INFORMATION GROUP

  • Aetna Life Insurance Company (Hartford, CT): Aetna Life Ins. & Annuity Co. (Hartford, CT); Aetna Life Ins. Co. of Illinois (Chicago, IL); Excelsior Life Ins. Co. (Toronto, Ont., Can.).

1983 0510/11 and 0728 - GOV - Tax treatment of life insurance

  • [PDF-974p, No Video] ->Not on govinfo.org
  • Subcommittee on Select Revenue Measures of the Committee on Ways and Means
  • The maximum guideline level premium under TEFRA for a male age 35 purchasing our universal life policy is $15.33 per thousand of insurance.
  • By contrast, the average level premium for participating whole life insurance sold by 25 of our larger competitors is $21.92 per thousand, and that is 43 percent greater.
  • Furthermore—and I find this most interesting—the actual average annualized premium received by Hutton is considerably less than the $15.33.
  • Actually, since TEFRA it has been $9.46.
  • I think these numbers clearly demonstrate that universal life is not an investment.

1983 0510/11 and 0728 - GOV - Tax Treatment of Life Insurance

    • [PDF-
    • Subcommittee on Select Revenue Measures of the Committee on Ways and Means
  • 1983 - LR - TEFRA's Conversion of Universal Life into the Flexible Premium Life Insurance Contract - 3 J.L. & Com. 325
  • 1985 - LR - Tefra's Responsse to Short-Term Abuses of Insurance Annuity Policies - Law and Contemporary Problems - p281-299 - 20p

https://www.congress.gov/search? searchResultViewType=expanded&q=%7B%22source%22%3A%22legislation%22%2C%22search%22%3A%22H.R.6045%22%2C%22congress%22%3A97%7D

BILL

1. H.R.6045 — 97th Congress (1981-1982)A bill to provide special temporary rules for taxing the income of life insurance companies.Sponsor: Rep. Holland, Kenneth L. [D-SC-5] (Introduced 04/01/1982) Cosponsors: (108)Committees: House - Ways and MeansLatest Action: 08/19/1982 See H.R.4961. (All Actions)Tracker: 

This bill has the status Introduced

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LAW

2. H.R.4961 — 97th Congress (1981-1982)Tax Equity and Fiscal Responsibility Act of 1982Sponsor: Rep. Stark, Fortney Pete [D-CA-9] (Introduced 11/13/1981) Cosponsors: (12)Committees: House - Ways and Means | Senate - FinanceCommittee Reports: S.Rept 97-494S.Rept 97-530H.Rept 97-404H.Rept 97-760Latest Action: 09/03/1982 Became Public Law No: 97-248. (TXT | PDF) (All Actions)