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IRS Proposes Separate Entity Treatment for a Cell
the taxable year is the issuing of insurance or annuity con- tracts or the reinsurance of risks underwritten ... its business was the issuing of insurance or annuity contracts or the reinsuring of risks underwritten ...- Authors: Lori J Jones, Janel C Frank
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Highlights of the Recent Guidance on Insurance Company Acquisitions
policy acquisition expens- es on life insurance and annuity contracts. The exist- ing rules in Treas. Reg. ... company’s reinsurance of liabilities under life, annuity and noncancellable acci- dent and health contracts ...- Authors: Lori J Jones
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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Proposed Regulations Would Deny Reserve Deductions for Certain Captives
Deductions for Certain Captives by Rick Gelfond and Yvonne S. Fujimoto FEBRUARY 2008 335 significant insurance ... may be reached at fgelfond@deloitte.com. Yvonne S. Fujimoto is an insurance tax manager with the Washington ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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When Are Guaranty AssociationAssessments Deductible?
When Are Guaranty AssociationAssessments Deductible? Statutory Statement of Accounting Principle ... Company v. United States, 97 AFTR 2d 2006-1542 (U.S. Ct. Fed. Cl. 2006), the question came up as to whether ...- Authors: Peter Winslow, Lori J Jones
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
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A Practical Guide for Determining Whether a Section 338h10 Election Should Be Made for a Target Insurance Company
deemed liquidation of Old Target into its shareholder[s].4 The liquidation may be treated as tax-free pursuant ... interpretation of the regulation. P. Winslow and S. Mitchell, Valuation of Insurance in Force for Tax ...- Authors: Lori J Jones
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Tax Aspects of Nonperforming Assets
Tax Aspects of Nonperforming Assets Comparison of statutory and tax accounting rules in treatment ... 9 In Cottage Savings Ass’n v. United States, 499 U.S. 554 (1991), the Supreme Court held that a material ...- Authors: Peter Winslow, Samuel A Mitchell
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
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Proration for Segregated Asset Accounts – Part Two
Proration for Segregated Asset Accounts – Part Two Update to initial article in Sept. 2007 issue, ... 432 (Part 2), 98th Cong., 2d Sess. 1420 (1984); S. Prt. Rep. No. 169 (Vol.I), 98th Cong., 2d Sess.- Authors: Susan Hotine
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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IRS to Rule on the Meaning of Statutory Reserves
IRS to Rule on the Meaning of Statutory Reserves Discusses the meaning of statutory reserves with ... to determine statutory reserves. I.R.C. § 816. S. Prt. 98-169, 98th Cong., 2d Sess., Vol. I (1984); ...- Authors: Peter Winslow, Samuel A Mitchell
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
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Fortuity, Or Not Fortuity … That Is the Question
already occurred.” United States v. Patryas, 303 U.S. 341, 345 (1938). the position that a contract of ... contract. See Merchants Mutual Ins. Co. v. Lyman, 82 U.S. 664, 21 L. Ed. 246, 247 (1872), where the Supreme ...- Authors: Frederic Gelfond
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting