retires. 1990s to present: Limited reform Ultimately, the IRS won court cases against several leveraged COLI investors, including Camelot Music, Winn-Dixie, American Electric Power, and Dow Chemical. Other similar investors settled their tax cases with the IRS on a basis mostly favorable to the IRS. Meanwhile, Congress amended the IRC several times again to both ensure that the prohibition on borrowing (on a deductible basis) to fund insurance acquisitions was clear and to deny the tax-free nature of death benefits to corporate employer in some situations (e.g., if the insured was not provided with adequate advance notice and an opportunity to block the insurance acquisition or if the insured was not an employee of the corporation within a year of his or her death). So long as the employer complies with the new rules (adopted in 2006 and characterized as the "COLI Best Practices Act"), however, the tax-free nature of the death benefits and the tax deferral on earnings credited to policy value remain. The COLI Best Practices Provision, within the Pension Protection Act of 2006, was signed into law on August 17, 2006. This provision is designed to codify industry "best practices" regarding employer-owned life insurance and amend the Internal Revenue Code of 1986 by introducing conditions that must be met in order to exclude from gross income the proceeds from company-owned life insurance. The Act amends Section 101 of the Internal Revenue Code by adding subsection (j), “treatment of Certain Employer-Owned Life insurance Contracts,” and adds Section 60391, “Returns and Records with respect to Employer-Owned Life Insurance Contracts.” Under Section 101(j), the employer-owned death benefit proceeds will be considered eligible for exclusion from the employer's income provided all the following Notice and Consent Requirements and one of the Specified Exceptions are met. Notice and Consent Requirements The Employee must, prior to the issuance of the insurance contract: Be notified in writing that the employer intends to insure the employee’s life and the maximum face amount for which the employee could be insured at the time the contract is issued. Provide written consent to be insured under the contract during and after active employment. Be informed in writing if the employer will be a sole or partial beneficiary of any death benefits. Specified Exception: The insured was an employee at any time during the 12-month period before the insured’s death. Specified Exception: Directors and Highly Compensated Employees: At time