A foreign currency denominated policy will be constantly changing value in US dollar terms. That change on its own should not be considered a material change imo, so no problems yet. However, let’s say there is a material change for another reason. Some formulas, such as determining the new GLP, include the old GLP in the calculation. Would I use the old GLP, using the initial death benefit in US dollars at the time of issue, and then use current coverage at the current amount death benefit using US dollars today? That seems correct to me, but also a pain, compared to just using the foreign currency death benefit amount with no change for currency fluctuations.
Not a real answer, but since the purpose behind 7702 is to limit the amount of funding in a life insurance policy to maintain some risk transfer, as long as the premiums, face amount and cash value are all denominated in the same currency, wouldn’t the funding relationships be fine?
Maybe. I know that the Canadian exempt test does need to take currency fluctuations into account, and it is possible to go offside because of it.