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Income tax is payable on proceeds from surrender of a life insurance policy used to repay a loan against the policy

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2014

In a recent income tax case, the Tax Court affirmed the principal that the proceeds received from surrender of an insurance policy in excess of the

Schwab v. Commissioner, 111 AFTR-2d 2013-667 (April 24, 2013)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • June 3 2013

The Court of Appeals for the 9th Circuit held that the "amount actually distributed" when taxpayers received ownership of life insurance policies was

IRS issues Revenue Ruling 2011-28

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • 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

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

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • 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
  • -
  • USA
  • -
  • 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