In a ruling rendered on June 4, 2013, FSC requires life insurers to include in promotion materials of life insurance or annuity insurance products a notation, in emphasis fonts, that although the death benefit under a life insurance policy or vested annuity payment under an annuity insurance policy made to the designated beneficiary shall not be deemed as the deceased’s estate pursuant to Article 112 of the Insurance Act, the tax authority may still take proper actions pursuant to the “principle of substantive taxation” under Article 12-1 of the Tax Collection Act should the circumstance involves evasion of the estate tax or other taxes.