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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...)
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