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Expert Analysis

Inside The New Hedges And Mixed-Straddles Tax Guidance

Law360, New York (August 18, 2014, 10:32 AM EDT) -- On July 18, 2014, the Treasury Department and the Internal Revenue Service unveiled two pieces of long-anticipated guidance that are particularly relevant to the life insurance industry. Specifically, the Large Business and International Division (LB&I) of the Internal Revenue Service released a directive addressing the federal income tax accounting for an insurance company's hedges of guaranteed minimum benefits provided under variable annuity contracts (the directive). In addition, the Treasury Department and the IRS published final regulations under IRC § 1092 concerning identified mixed straddles (the final regulations). We describe the directive and the final regulations in greater detail below....

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