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December 12, 2006



Pension Protection Act Provides Tax Relief to Purchasers of Long-Term Care Contracts

Changes to the tax code enacted by the Pension Protection Act (Pub. L. No. 109-280) will provide incentives to purchase long-term care insurance by providing purchasers with attractive tax benefits, American Council of Life Insurers Senior Vice President (taxes and retirement security) Ann Cammack told BNA Dec. 4.

First, the law amended tax code Section 72, so that distributions from the cash surrender value of life insurance or annuity contracts used to pay premiums for long-term care riders to the contracts are excluded from taxable income.

The legislation also amends Section 7702B to treat as qualified long-term care a long-term care rider to an annuity or life insurance contract, which generally will exclude premium fees from taxable income.

The changes essentially mean that any charge against the cash value of an annuity contract or cash surrender value of a life insurance contact made as payment for a qualified long-term care contract rider, or supplement, is excludable from taxable income.

“The hope from a policy standpoint is that this will encourage people to acquire protection from catastrophic illnesses,” Cammack said.

The pension law sections generally are effective for contracts issued after Dec. 31, 1996, but only with respect to taxable years beginning after Dec. 31, 2009, the law said.

Thomas Advocates Change.

The changes were championed by outgoing House Ways and Means Chairman William Thomas (R-Calif.), who viewed the language as a way to provide taxpayers with multiple benefits from a single pool of assets, Cammack said.

“The idea is that perhaps it makes it more appealing for the individual to consider [purchasing] long-term care when they acquire an annuity or life insurance contract by providing that the distribution of the assets of the contact is a tax free distribution,” she said.

The law also amends Section 1035(b) to expand the types of insurance policies that may be exchanged in a tax-free transaction as well as amending information reporting requirements contained in Section 61. Both of those changes are effective for transactions occurring after Dec. 31, 2009.

Industry Response.

The change to Section 72 mean that monies taken out of a contract's cash value used to pay long-term care rider fee premiums will not be treated as a taxable event, but such transactions will reduce the investment in the contract, but not below zero.

Section 7702 will deny a Section 213 medical expense deduction for any payments made for coverage under a qualified long-term care insurance contract if the payment is made as a charge against the cash surrender value of a life insurance contract or the cash value of an annuity contract.

Cammack said combination insurance products that link life insurance and annuities with long-term care insurance currently are available on the insurance market but that consumer appetite for the riders likely will increase due to the pension act provisions. “This is a market [insurance companies] see opening up for them,” she said.

“This is strictly a question of how the product is treated for tax purposes. There are companies that sell combination annuity and long-term care contacts today; they just don't get the same tax preference as they will in the future,” she added

By Stephen Joyce


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