Modco – Modified Coinsurance 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…

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1035 – International Revenue Code (IRC) Another section that’s totally new in the Senate bill is sort of a curiosity piece – Section 1035. The old, seldom-noticed provision of 1035 was that the life insurance and endowment contracts that qualify for 1035 exchanges must be issued by companies taxed under Section 801, meaning life insurance…

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Taxonomy – Changes – Term to Permanent A few companies have introduced a product known as Universal or Total Life. The concept involves…the company withdraws an amount sufficient to pay the premiums for an annual renewable term coverage for the amount selected for the for the current policy year. (p70) 1982 – Book – Life…

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Life Insurance Company Taxation Government Hearings Pete Stark 1989 – “Final Report to The Congress on Life Insurance Company Taxation”  fraser.stlouisfed.org/title/press-releases-united-states-department-treasury-6111/volume-292-587135 3. Correspondence from the American Council Of Life Insurance <ACLI> concerning proposals for the taxation of life insurance companies. (Attachment One-B) —  Report of the Life & Health Actuarial Task Force to the Technical…

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Corridor Chairman Pete STARK (D-CA):  Or, on the other hand, do you think we should get into more of the definition, as Mr. Gregg suggested we did in TEFRA, where we spell out percentages of cash value to face value? <Gregg, Thomas, National Association of Life Underwriters..> (p328) 1983 0510, 0511 and 0728 – GOV…

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Tax Codes 101 – IRC – Internal Revenue Code 818 – Reserves 820 – Modco 1035 7702 Cash Value Accumulation Test (CVAT), Guideline Premium Test (GPT), Corridor Test, 7-Pay, and Modified Endowment Contract (MEC).  ecfr.gov congress.gov JOINT COMMITTEE ON INTERNAL REVENUE TAXATION – archives.gov///chapter-23-joint-internal-revenue-taxation.html 1984 – DEFRA Cash Value Accumulation Test (CVAT) and the Guideline Premium Test…

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TEFRA – DEFRA – TAMRA 1982 – TEFRA – Tax Equity and Fiscal Responsibility Act of 1982 https://www.congress.gov/bill/97th-congress/house-bill/4961 1983 – Life Insurance Tax Act of 1983 1984 – DEFRA H.R. 4170 (98th): Deficit Reduction Act of 1984 Tax Reform Act of 1984 PUBLIC LAW 98-369—JULY 18, 1984 https://www.govinfo.gov/content/pkg/STATUTE-98/pdf/STATUTE-98-Pg494.pdf 1988 –  Technical and Miscellaneous Revenue Act of 1988…

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1985 0719 – GOV (House) – Impact of Tax Reform on Insurance Industry – Stark 1985 0719 – GOV (House) – Comprehensive Tax Reform (9parts), (CSPAN) Impact of Tax Reform on Insurance Industry, Pete Stark (D-CA)  —  [BonkNote] [PDF-GooglePlay-Part 7 of 9-1175p,  VIDEO-CSPAN] House – Committee on Ways and Means Witnesses testified on the effects that President Ronald…

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Inside Buildup These two meetings, plus the announced intention of some members of Congress and the Treasury Department to consider taxing the inside buildup of cash values, adds a note of uncertainty to our discussion today.  —  Paul J. Overberg 1983 – SOA – Individual Life Insurance, Society of Actuaries – 22p JULY 19, 1985 Impact of…

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