The Taxpayer Relief Act of 1997 furnishes the courts and the Internal Revenue Service an opportunity to close certain loopholes in the federal tax consequences of assigning life insurance. About twenty years ago, we published an article arguing that the tax consequences of assigning life insurance affords taxpayers unwarranted opportunities for tax avoidance. Since then, developments in the case law and Internal Revenue Service rulings have broadened the loopholes. In the update of our article, we show how the new tax law supports our original position.
Waggoner, Lawrence W. "Tax Consequences of Assigning Life Insurance - Time for Another Look." D. A. Kahn, co-author. Fla. Tax Rev. 4, no. 5 (1999): 381-416.