BREAKING: PPP Deductibility and Low Interest Rate Relief for Life Insurance Year End Deal Over the weekend, Congress was able to overcome months of stalemate and agree on a 900+ billion dollars COVID stimulus package which will be included with the year-end omnibus legislation to fund the federal government. After the CARES Act, the economic...
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Finseca December Alert DOL Finalizes the Fiduciary Rule and Rollover Guidance, but It May Be Too Little, Too Late: What Producers Should Know About the Details and the Timing In July, the U.S. Department of Labor (“DOL”) proposed a new and somewhat controversial regulatory and guidance package commonly called the “Fiduciary Rule.” The new package…
Final DOL Fiduciary released but faces uncertain future with incoming Biden Administration Last night the Department of Labor’s Fiduciary rule cleared OMB and now awaits publication in the federal register, becoming effective in sixty days after that date. Because of the delay coming out of the Department, the rule will not become effective until after…
Update: COLI/BOLI Reportable Policy Sale / Transfer for Value Treasury Regulations
Topics: COLI/BOLI, Transfer for value
March 10, 2020 WRN 20.03.10 Update: COLI/BOLI Reportable Policy Sale / Transfer for Value Treasury Regulations Disclaimer This memorandum is not intended to constitute tax or legal advice. Reminder Asset based mergers that include life insurance have always been treated as Transfers for Value affecting the taxation of the death benefits. Nothing in the Tax…
Information for Clients: Impact of Final Regulations on Reportable Policy Sales in the COLI/BOLI Marketplace
Topics: COLI/BOLI
The Tax Cuts and Jobs Act of 2017 (the “TCJA”) modified the prior-law exemptions of the Transfer for Value Rules (“TFV Rules”) to include new Reportable Policy Sale (“RPS”) requirements that apply to all transfers for valuable consideration. This rulemaking has important implications for the company-owned life insurance (“COLI”) and bank-owned life insurance (“BOLI”) marketplaces…
Implications of the Treasury Department’s Final Regulations on Reportable Policy Sales for 1035 Exchanges Made by Businesses
Topics: COLI/BOLI
On October 31, the Treasury Department released its final regulations on Reportable Policy Sales (RPS) final rule. In addition to clarifying the tax implications for company-owned life insurance (“COLI”) and bank-owned life insurance (“BOLI”) transferred in ordinary course transactions, the rule also cemented the Treasury Department’s position on how the requirements will apply with respect…
Impact of the Treasury Department’s Final Regulations on Reportable Policy Sales on COLI/BOLI Marketplace
Topics: Transfer for value
Disclaimer This memorandum is not intended to constitute tax or legal advice. The Regulation https://www.govinfo.gov/content/pkg/FR-2019-10-31/pdf/2019-23559.pdf Publication Date: October 31, 2019 Background The Tax Cuts and Jobs Act of 2017 (the “TCJA”) modified the prior-law exceptions of the Transfer for Value rules (“TFV Rules”) to include a new reportable policy sale requirement that is applicable to…