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Internal Revenue Code (IRC) Insurance Industry Life Insurance

Gerald Nowotny - Law Office of Gerald R....

Still the One! – The Use of Private Placement Life Insurance in Tax Planning for Trial Attorneys with Contingency Fee Income

In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more

Gerald Nowotny - Law Office of Gerald R....

Las Mañanitas

Recently (January 15th) I celebrated my sixty fifth birthday. Where did the time go? If my East German father Willy Wolfgang Nowotny were still with us, I could hear him say, “Too soon old, too late smart.” While I was never...more

Levenfeld Pearlstein, LLC

Another Attack on Private Placement Life Insurance

The use of private placement life insurance (PPLI) by high-net-worth individuals has generated considerable controversy over the years, with proponents arguing that it is a proper use of existing laws that provide many of the...more

Gerald Nowotny - Law Office of Gerald R....

All in the Family – Introducing Family-Owned Life Insurance™ (aka FOLI)

Perhaps you are tired of reading that I grew up in the Panama Canal Zone, but it is one of the last bastions of American colonialism. Personally, I do not like the word “colonialism” because it inevitably conjures up negative...more

Eversheds Sutherland (US) LLP

IRS issues simplified procedures for insurance companies to change methods of accounting to comply with amended Section 846

The Internal Revenue Service (IRS) recently released two revenue procedures that relate to the implementation of accounting method changes as a result of the revisions to Section 846 of the Internal Revenue Code of 1986, as...more

Eversheds Sutherland (US) LLP

IRS issues key audit directive for life insurers

The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers. The IDD is the product of a two-year...more

Eversheds Sutherland (US) LLP

IRS Provides Guidance on Reasonable Mortality Charges for Life Insurance Contracts Based on 2017 CSO Tables

On October 19, the Internal Revenue Service (IRS) issued an advance version of Notice 2016-63, addressing the “reasonable mortality charge” requirement under IRC §§ 7702 and 7702A for life insurance contracts based on the...more

Cadwalader, Wickersham & Taft LLP

New 871(m) Regulations Finalize Dividend Equivalent Payment Withholding Rules for Equity Derivatives

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code (collectively, the “new regulations”) that provide the rules for...more

Carlton Fields

For Life Insurers and Agents – A Summary of Predicted Litigation Under the DOL’s Proposed Fiduciary Rule

Carlton Fields on

The Department of Labor’s recent Proposed Rule (the “Proposal”), which defines the term “fiduciary” as it applies to persons who provide “investment advice” to ERISA plans and IRAs, will impact the likelihood and severity of...more

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