WHERE HAVE YOU GONE, CHIP HILTON?
Somewhere Over the Rainbow
Investment Management Roundtable Discussion – Personal Estate Planning
The National Association of Insurance Commissioners (NAIC) held its 2021 Fall National Meeting from December 11 to 16 in San Diego, California. The meeting was held in a hybrid in-person and remote format due to the ongoing...more
In June, the IRS issued two private letter rulings (PLRs) dealing with fee-based annuities. The facts of these two PLRs are generally identical to the facts of 17 PLRs issued by the IRS last November, with one important...more
The Internal Revenue Service (IRS) released proposed regulations amending Employment Tax Regulations (26 CFR Parts 31 and 35) under section 3405 of the Internal Revenue Code (IRC). The regulations propose new rules for...more
People complain a lot about life these days, but one fun fact is that people are living longer than they did just 20 years ago. Thankfully, the Internal revenue Service (IRS) noticed too....more
In Notice 2019-18, the Internal Revenue Service (the “IRS”) changed its position and now will permit employers to offer lump sum payments to retirees who are currently receiving annuity payments from a defined benefit plan....more
On its current course, this year could be both the best and the worst of times for insurance. The US economy continues to enjoy steady growth, stock indices continue to reach new highs and tax reform in the US allows both...more
As reported in our November 28 client alert, the National Association of Insurance Commissioners’ (NAIC) Annuity Suitability Working Group (Suitability WG) circulated the proposed Suitability and Best Interest Standard of...more
Last month, we wrote about potential litigation issues under the “revised temporary” DOL Rule involving the offer and sale of annuities in the IRA market. This paper continues that discussion. I emphasize to the reader that...more
Previously, I wrote about potential litigation under the Department of Labor’s then proposed fiduciary rule (see Expect Focus, Vol. II, 2015). I predicted the following as to sales of index annuities to IRAs if the rule was...more
The CFPB filed suit against J.G. Wentworth, LLC on June 7, 2016 after the company challenged the Bureau’s expansive view of its jurisdiction. The CFPB served a CID against J.G. Wentworth, LLC on September 11, 2015 to...more
The National Association of Insurance Commissioners (NAIC) Spring 2016 National Meeting, which was held from April 3 – 6 in New Orleans, offered insight into numerous issues being considered by state commissioners nationwide....more
Overview - It is an understatement to say that the state of affairs in the offshore landscape is in flux. The fallout from the recent scandal in Panama remains to be seen. The fall of the rich and famous may end up...more
On April 10, the Internal Revenue Service (IRS) released PLR 201515001 (Oct. 10, 2014), favorably addressing a “taxable annuity”—essentially, a deferred annuity contract supported, in part, by subaccounts, each of which...more
Former and current annuity holders sued John Hancock Life Insurance Company in New Jersey federal court several years ago, alleging that, as a service provider to their 401(k) plans, John Hancock was an ERISA fiduciary and...more