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Why Do Limitations Apply to Owners of Life Insurance Contracts, Particularly COLI?
Contracts, Particularly COLI? By Bryan W. Keene and Mark S. Smith It is well known that permanent, cash value ... on any life insurance policy, or endowment or annuity contract, if the taxpayer is directly or indirectly ...- Authors: Bryan W Keene, Mark Smith
- Date: Jun 2019
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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IRS Ruling Confirms Exchange of COLI on Former Employees Triggers Loss of Interest Deductions
purposes of sections 72(q)(2) (I) and (u)(4) (defining an “immediate annuity”).8 Absent a similar directive ... rates guaranteed on issuance of the contract, or mortality and expense charges) are the same as the terms ...- Authors: John Adney, Bryan W Keene
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Life Insurance
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Taxing Times, May 2006, Volume 2, Issue No. 1
related to life insurance companies, insurance and annuity products and employee benefit plans.” However, ... require us to collectively bring our expertise to the table. Thus, I am urging existing members of the Taxation ...- Authors: Application Administrator, Barbara Gold, William B Harman, Douglas N Hertz, Brian King, Kory Olsen, Bryan W Keene, Joseph F McKeever
- Date: May 2006
- Publication Name: Taxing Times
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Rev. Proc. 2008-41—Correction of Inadvertent Diversification Failures
Rev. Proc. 2008-41—Correction of Inadvertent Diversification Failures This article discusses ... diversification requirements applicable to variable annuity and life insurance contracts under section 817h ...- Authors: Bryan W Keene, Joseph F McKeever
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Life Insurance; Public Policy
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Additional IRS Rulings on Contingent Deferred Annuities
involved in the new rulings, which was a group annuity contract, provided guaranteed lifetime withdrawal ... reporting obligations. FACTS OF THE NEW RULINGS P L R s 2 0 1 1 1 7 0 1 2 a n d 201117013 were companion ...- Authors: John Adney, Bryan W Keene
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Annuities
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Congress Clarifies Treatment of Partial Annuitizations
rule that applies to withdrawals and other non-annuity payments. Treasury Department and Internal Revenue ... endow- ment contracts, in addition to those under annuity contracts, but this article focuses on the latter ...- Authors: Bryan W Keene
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities
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Life Settlements: Congress Wades Into the Fray
$7.01 billion.17 According to a 2011 report, the U.S. life settlement industry saw sales drop about 50 ... challenges facing their industry. Fears that the U.S. economy could fall into a “double-dip” recession ...- Authors: John Adney, Bryan W Keene
- Date: Oct 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Health & Disability; Life Insurance; Public Policy
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T3: TAXING TIMES Tidbits
the premiums paid for that contract and any “mortality credits” applied to it pursuant to an experience ... all cost of insurance (“COI”) charges and net mortality and expense (“M&E”) charges previously imposed ...- Authors: Application Administrator, Charles J Auer, Craig Pichette, Bryan W Keene, Peter Winslow, Janel C Frank, Gregory K Oyler, Michael Edward Bauer
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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IRS Rules Lifecycle Funds Comply with Investor Control Doctrine
IRS Rules Lifecycle Funds Comply with Investor Control Doctrine Discusses PLR 201105012, the ... available only through a life insurance company's separate account, still can be considered owned by ...- Authors: Bryan W Keene
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Annuities>Variable annuities; Life Insurance
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T3: Taxing Times Tidbits
certificate owner: (1) the certificate is an “annuity contract” within the meaning of section 72;2 ... the previous PLRs: • Amounts received as an annuity. First, the IRS ruled that if the insurer becomes ...- Authors: Application Administrator, Craig R Springfield, Bryan W Keene, Biruta P Kelly
- Date: May 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities>Guaranteed living benefits; Financial Reporting & Accounting>Tax accounting; Long-term Care>Long-term care insurance