An article on notes that the IRS  recently published  PLR 201417007 (released April 25, 2014), which provides some additional clarification with respect to the structuring of insurance-dedicated funds (IDFs).

The IRS ruled favorably that certain factors would not cause variable contract owners to be taxed on a current basis on fund gains due to certain factors.  See full article at IRS Clarifies the Structuring of Insurance-Dedicated Funds | Insurance content from

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.