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T3: TAXING TIMES TIDBITS
In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign ... foreign parties changing the counterparty obligated to a domestic corporation (“Taxpayer”) under an existing ...- Authors: Frederic Gelfond
- Date: Aug 2021
- Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Reinsurance; Reinsurance>General reinsurance
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FATCA and Insurance – Fundamental Questions Remain Unanswered as Compliance Deadline Approaches
FATCA and Insurance – Fundamental Questions Remain Unanswered as Compliance Deadline Approaches ... Approaches Discusses the impact of the Foreign Account Tax Compliance Act, FATCA, on U.S. insurance industry ...- Authors: Frederic Gelfond, Mary Gillmarten
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Financial Reporting & Accounting
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Recent Guidance Involving the Taxation of Life Settlement Transactions
Guidance Involving the Taxation of Life Settlement Transactions A discussion of new IRS rulings with ... with respect to the taxation of life settlement transactions. Capital gains;Internal Revenue Service=IRS;Life ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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IASB Exposure Draft on Insurance Contracts
Exposure Draft on Insurance Contracts Discusses the IASB insurance contract project and the major components ... components of the new accounting standard, including the guidance it provides regarding how to define the term ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: May 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>International Accounting Standards Board [IASB]; Financial Reporting & Accounting>International Financial Reporting Standards [IFRS]
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Fortuity, Or Not Fortuity … That Is the Question
Fortuity, Or Not Fortuity … That Is the Question Examines the Treasury Department and IRS guidance in ... federal tax law. It concerns the concepts of fortuity, homogeneity, and risk distribution, among others ...- Authors: Frederic Gelfond
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Taxing Times, May 2007, Volume 3, Issue No. 2
Taxing Times, May 2007, Volume 3, Issue No. 2 Full version of Taxing Times, May 2007, Volume ... Times, May 2007, Volume 3, Issue No. 2 Full version of Taxing Times, May 2007, Volume 3, Issue No. 2. 26420 ...- Authors: Application Administrator, Christian J DesRochers, Edward Robbins, Leslie Chapman, Brian King, Kory Olsen, Frederic Gelfond, Craig R Springfield, Bryan W Keene, Peter Winslow
- Date: May 2007
- Publication Name: Taxing Times
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COLI Update - Court Decides Xcel Had Insurable Interest In Broad-Based COLI and Sixth Circuit Overturns Taxpayer-Favorable Decision in Dow Chemical COLI Case
products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest ... Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns ...- Authors: Frederic Gelfond, Susan Hotine, Peter Winslow
- Date: May 2006
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; Technical Skills & Analytical Problem Solving>Innovative solutions
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Investor Control: Will You Know It When You See It?
When You See It? On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control ... Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets ...- Authors: Ann Cammack, Frederic Gelfond
- Date: Mar 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Selected Insurance and International Tax Considerations for Investors in Life Settlement Businesses
This article is a discussion about the life settlement industry and the tax considerations for life insurance ... insurance bought and sold in the secondary market. Internal Revenue Service=IRS;Taxes=Taxation; 11557 ...- Authors: Frederic Gelfond
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance
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Proposed Regulations Would Deny Reserve Deductions for Certain Captives
34 4TAXING TIMES On Sept. 27, 2007, the Internal Revenue Service (IRS) and the Treasury Department ... consolidated group intercompany insurance trans- actions. The proposed rules would technically still require certain ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting