COLI Best Practices

(included as§101(j) of the Pension Protection Act of 2006)

Overview

AALU Washington Reports
“AALU Washington Reports are the property of the Association for Advanced Life Underwriting and are included for informational purposes only. Applicable copyright laws apply.”

Bulletin

07-101

07-101A

Subject

IRS Issues Regulations on COLI Reporting

Summary

The Internal Revenue Service has issued proposed and temporary regulations under Revenue Code section 6039I, which requires employers who maintain COLI contracts subject to section 101(j) to file annually a report with the Service. The regulations are non-substantive and essentially provide the authority for the IRS to issue new Form 8925 – Report of Employer-Owned Life Insurance Contracts, which employers with COLI contracts will most likely have to file beginning with the 2007 tax year.


409A

(included in American Jobs Creation Act)

Overview

AALU Washington Reports “AALU Washington Reports are the property of the Association for Advanced Life Underwriting and are included for informational purposes only. Applicable copyright laws apply.”

Bulletin

08-80

Subject

Full Compliance with the Final 409A Regulations Required by the End of 2008

Summary

All non-qualified deferred compensation arrangements that are subject to Internal Revenue Code section 409A must be in full compliance by the end of 2008 with the final regulations under that section. With less than four months remaining in 2008, plan sponsors that are not in full compliance should take action now to ensure that they can be fully compliant by the end of the year…

Bulletin

07-50

Subject

Additional Analysis of Pre-September 18, 2003 Split-Dollar Life Insurance Arrangements and Section 409A

Summary

IRS Notice 2007-34 was issued in conjunction with the final regulations under Revenue Code section 409A to provide guidance regarding the application of that section to split-dollar life insurance arrangements….

Bulletin

07-48

Subject

AALU Teleseminar On Final 409A Regulations and Notice 2007-34

Summary

This Washington Report summarizes the questions that were addressed in a Teleseminar sponsored by the AALU on April 23, 2007 with respect to the recently released final regulations under Code Section 409A and Notice 2007-34. The Notice provides specific guidance regarding the application of 409A to split-dollar life insurance arrangements…

Bulletin

07-44

Subject

Additional Analysis of Final 409A Regulations

Summary

This Washington Report fulfills our promise to provide a detailed analysis of the just issued Code section 409A final regulations. (See our Bulletins Nos. 07-41 and 07-38.) IRS Notice 2007-34, which was released in conjunction with the final regulations, provides specific guidance regarding the application of section 409A to split-dollar life insurance arrangements…

Bulletin

07-41

Subject

Additional Analysis of IRS Notice 2007-34 – Guidance for Applying 409A To Split-Dollar Life Insurance Arrangements

Summary

As announced in our Washington Report No. 07-38, the Internal Revenue Service issued last week the long-awaited final regulations under Revenue Code section 409A along with IRS Notice 2007-34, which provides specific guidance regarding the application of that Code section to split-dollar life insurance arrangements….

Bulletin

07-111

Subject

IRS Releases Limited Correction Program for Section 409A Violations.

Summary

The IRS recently released its long-awaited correction program under section 409A. In its current form, the correction program is very limited as to the types of corrections that can be fixed under this program.

Bulletin

07-109

Subject

Additional Analysis of IRS Guidance On 2007 Reporting and Withholding Under Code Section 409A

Summary

The deferred compensation rules under Revenue Code section 409A impose new reporting and withholding requirements that were effective with respect to amounts deferred on or after January 1, 2005. The IRS recently issued Notice 2007-89, which provides guidance for complying with the reporting and withholding requirements for 2007. This Bulletin provides a more detailed discussion of Notice 2007-89.


Banking Industry Regulatory Guidance

FDIC: FIL-127-2004
OCC: OCC 2004-56
Federal Reserve: SR 04-19


Financial Accounting Resources

The Financial Accounting Standards Board (FASB) Accounting Standards Codification™ is now the single source of authoritative nongovernmental U.S. Generally Accepted Accounting Principles (GAAP). All existing accounting standard documents are superseded. All other accounting literature not included in the Codification will be considered nonauthoritative.

Following is a list of topics related to Nonqualified Deferred Compensation (NQDC) Plans, informal funding and accounting for income taxes. The first link provides a cross-reference between previous guidance and the Accounting Standards Codification™.

Cross-ReferenceClick Here to Download
Accounting for Purchases of Life Insurance – ASC 325-30 (FASB-TB 85-4 and EITF 06-5)Click Here to Download
Deferred Compensation Contracts – ASC 710 (APB 12 as amended by SFAS 106)Click Here to Download
Employers’ Accounting for Pensions – ASC 715-30 (SFAS 87)Click Here to Download
Employers’ Accounting for Postretirement Benefits other than Pensions – ASC 715-60 (SFAS 106)Click Here to Download
Accounting for Postretirement Benefit Endorsement Split-Dollar Life Insurance Arrangements – ASC 715-60 (EITF 06-04)Click Here to Download
Accounting for Postretirement Collateral Assignment Split Dollar Life Insurance Arrangements – ASC 715-60 (EITF 06-10)Click Here to Download
Accounting for Income Taxes – ASC 740 (SFAS 109)Click Here to Download