The ABA Tax Section offers a teleconference and webcast today on New IRS Correction Procedures — Life Insurance and Annuity Contracts from 1:00 – 2:30 p.m. EST:

On June 30, 2008, the IRS issued five revenue procedures that significantly changed the process for correcting compliance failures under section 7702 (defining “life insurance contract” for tax purposes), section 7702 (defining “modified endowment contract” for tax purposes), and under section 817(h) (imposing diversification requirements for variable life insurance and variable annuity contracts).

The five revenue procedures (Rev. Proc. 2008-38 through Rev. Proc. 2008-42) were developed as the need for improved procedures became more and more evident, particularly with respect to the formal cost of correction, i.e., the “toll-charge,” and in response to the Service and Treasury’s request for comments that was made in Notice 2007-15. The updated procedures make significant changes to the requirements for correction.

Speakers:

• John T. Adney (Davis & Harman, Washington, D.C.)
• Michelle A. Garcia (Davis & Harman, Washington, D.C.)
• Mark E. Griffin (Davis & Harman, Washington, D.C.)
• Bryan W. Keene (Davis & Harman, Washington, D.C.)
• Susan E. Seabrook (Latham & Watkins, Washington, D.C.)
• Craig R. Springfield (Davis & Harman, Washington, D.C.)
• Daniela Stoia (Davis & Harman, Washington, D.C.)