De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021): Split-dollar Insurance Benefits Were Compensation, Not a Distribution

The U.S. Tax Court in De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021), issued a “reviewed opinion” holding that economic benefits received by the taxpayer-husband under a split-dollar arrangement were not “distributions” under Code Sec. 301, but were benefits received under a compensatory arrangement and as such were taxable as “compensation … Continue reading De los Santos v. Commissioner, 156 TC No. 9 (April 12, 2021): Split-dollar Insurance Benefits Were Compensation, Not a Distribution

PLR 202109002 and PLR 202109003 (Mar. 8, 2021): Investment Advisory Fees Not Treated as “Amount Received” for Code Sec. 72(e) Purposes for Annuity Contracts

In PLRs 202109002 and 202109003, the Service ruled that t certain annuity contract investment advisory fees are not treated as amounts received by the contract owner for Code Sec. 72(e) purposes. The taxpayers were insurance companies offering non-qualified deferred annuity contracts. The IRS stated observed that the fees, which were integral to the contracts, did … Continue reading PLR 202109002 and PLR 202109003 (Mar. 8, 2021): Investment Advisory Fees Not Treated as “Amount Received” for Code Sec. 72(e) Purposes for Annuity Contracts

Fox Business: Prudential suspends applications for some life insurance policies (Apr. 7, 2020)

Fox Business has reported that Prudential Insurance is suspending applications for some life insurance products during the Coronavirus Pandemic. Their article beings as follows: Americans seeking life insurance coverage have one less option to choose from, as one of the industry's major players announces coronavirus-related changes.Prudential said it would suspend its acceptance of applications for … Continue reading Fox Business: Prudential suspends applications for some life insurance policies (Apr. 7, 2020)