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IRS issues Revenue Ruling 2011-28

Proskauer Rose LLP
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USA
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January 9 2012

On December 5, 2011, the IRS issued Revenue Ruling 2011-28, holding that a grantor's retention of the power, exercisable in a non-fiduciary capacity, to acquire a life insurance policy held in a trust by substituting other assets of equal value will not cause inclusion of the policy in the grantor's gross estate under IRC Section 2042, as long as certain guidelines are met

Pruco Life Ins. Co. v. Brasner (S. D. Florida, November 14, 2011)

Proskauer Rose LLP
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USA
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January 9 2012

A U.S. District Court in Florida held that an investor who acquired a life insurance policy under a stranger owned life insurance ("STOLI") arrangement lacked an insurable interest, and that the insurer did not have to pay the $10 million death benefit

McGowen v. Comm’r, 2011 U.S. App. Lexis 18407 (10th Cir., Sept. 2, 2011)

Proskauer Rose LLP
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USA
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November 15 2011

The Tenth Circuit has affirmed a Tax Court decision finding that a taxpayer who borrowed against the cash value of an insurance policy must realize income under I.R.C. 72 when the policy was terminated by the carrier

Tax Court finds that life insurance proceeds were estate tax includible on account of decedent’s retained incidents of ownership, that annuities were estate tax includible, and that estate was liable for failure to file timely penalty Estate of Coaxum v

Proskauer Rose LLP
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USA
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August 5 2011

In Coaxum v. Commissioner, the Tax Court found that the decedent retained incidents of ownership in six life insurance policies, rendering their values includible in the gross estate, that the value of the annuities owned by the decedent was includible in the gross estate, and that the estate was liable for a failure to file timely penalty

Insurance policy in pension plan will be treated as ordinary life insurance contract and death benefits considered incidental if less than 50 of the participant’s total contributions to the plan are applied to pay premiums on the life insurance contract

Proskauer Rose LLP
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USA
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December 6 2010

In Private Letter Ruling 201043048 (10292010), IRS ruled that an insurance policy in a pension plan will be treated as an ordinary life insurance contract and the death benefits will be considered incidental, as less than 50 of the participants' total contributions to the plan were applied to pay premiums on the life insurance contract

Current Search

Jurisdiction - USA
Author - David Pratt
Author - Elaine Bucher
Author - Mitchell M Gaswirth
Author - Albert W Gortz
Firm Name - Proskauer Rose LLP
Workarea - Insurance & Reinsurance