- 14 - legislative history of section 7702(a). The conference report for the Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494, states with respect to the statutory definition in section 7702(a) that “A life insurance contract is defined as any contract, which is a life insurance contract under the applicable State or foreign law” (as long as the contract also meets one of two conditions not relevant here). H. Conf. Rept. 98-861, at 1075 (1984), 1984-3 C.B. (Vol. 2) 1, 329 (emphasis added). This interpretation is further supported by legislative history of the Technical and Miscellaneous Revenue Act of 1988 (TAMRA), Pub. L. 100-647, 102 Stat. 3342. TAMRA sec. 6078, 102 Stat. 3709, added section 7702(j), which treats certain church self-funded death benefit plans as “life insurance contracts” by exempting them from the section 7702(a) requirement that they be life insurance contracts “under the applicable law”.5 The legislative history 5 Sec. 7702(j) provides as follows: SEC. 7702(j). Certain Church Self Funded Death Benefit Plans Treated as Life Insurance.-- (1) In general.--In determining whether any plan or arrangement described in paragraph (2) is a life insurance contract, the requirement of subsection (a) that the contract be a life insurance contract under applicable law shall not apply. (2) Description.--For purposes of this subsection, a plan or arrangement is described in this paragraph if-- (A) such plan or arrangement provides for the payment of benefits by reason of the death of the (continued...)Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011