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IRS Provides Relief for Late Rollovers with New Self-Certificate
rollovers. With the publication of Rev. Proc. 2016-17, however, the IRS showed its intent was not to cre- ... the mental condition or incapacity of the taxpayer,17 or the erroneous advice of a financial advisor not ...- Authors: Michael Byro
- Date: Feb 2017
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
- Topics: Public Policy
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The Open Transaction Doctrine Applies to the Sale of Stock of a Demutualized Life Insurer in Fisher, But Should It?
considerable merit. … MAY 2010 TAXING TIMES | 17 CONTINUED ON PAGE 18 In the landmark case of Burnet ... 3 THE OPEN TRANSACTION DOCTRINE … | FROM PAGE 17 Emanuel Burstein is the author of Federal Income ...- Authors: Emanuel Burnstein
- Date: May 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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PLR 200906001 – A Conservative Taxpayer or a Very Subtle Message from the IRS?
of the insured of which the company is aware).”17 What is puzzling is what applicability the TAMRA ... under both sections 7702 and 7702A). 3 Oct. 17, 2008. A private letter ruling is issued to a particular ...- Authors: Daniela Stoia, Joseph F McKeever
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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The Road to the Remediation Revolution: A Short History of the Correction Procedures for Life Insurance and Annuity Contracts
whole.” After the issuance of Revenue Ruling 91-17, the Service saw an increase in waiver ruling requests ... correction programs announced in Revenue Ruling 91-17 and Revenue Procedure 92-25, analogized to ...- Authors: Application Administrator, Walter Welsh, Alison R Peak
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy
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Insurance Transfer Pricing: Issues For Life Reinsurance Transactions
PRICING … | FROM PAGE 15 MAY 2009 TAXING TIMES | 17 ized in different ways based on the way in which ... the actuarial method as an “unspecified method.”17 Regulations 1.482–4(e) provide an “unspecified ...- Authors: Christian J DesRochers
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance
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ACLI Update
ACLI Update Update on industry action on legislative and tax regulatory items affecting the ... particularly adverse impacts on life insurers. On June 17, ACLI submitted a comment letter to Treasury/IRS ...- Authors: Pete Bautz, Mandana Parsazad, Regina Y Rose
- Date: Oct 2016
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Public Policy
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T3: Taxing Times Tidbits
See, e.g., PLR 200339015 (June 17, 2003) and PLR 200339016 (June 17, 2003), both involving critical ... 2 2008-29 I.R.B. 160, amplifying Rev. Rul. 91-17, 1991-1 C.B. 190. Rev. Proc. 2008-42 provides the ...- Authors: Mark E Griffin, Craig R Springfield, Daniela Stoia, Biruta P Kelly
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy; Reinsurance
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Recent Developments on Policyholder Dividend Accruals
fixing of liability.” The Court cited Washington Post,17 Hughes Properties18 and Revenue Ruling 2011-2919 ... United States, No. 07-648T (Fed. Cl. Jan. 30, 2012). 17 405 F.2d 1279 (Ct. Cl. 1969). 18 476 U.s. 593 (1986) ...- Authors: Peter Winslow, Brion Graber
- Date: May 2012
- Competency: Strategic Insight and Integration>Effective decision-making
- Publication Name: Taxing Times
- Topics: Public Policy
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The Demise of Sections 809 and 815
REVIEW 31 (January 2001). MAY 2006 327 industry.17 Moreover, the enactment of the Gramm- Leach-Bliley ... Will Congress turn to these provisions next? 3 17 In 2003, stock life insurance companies held approximately ...- Authors: William B Harman, Douglas N Hertz, Bryan W Keene
- Date: May 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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What’s on the Shelf? A Proposal to Tax the Inside Buildup
| FROM PAGE 15 SEPTEMBER 2009 TAXING TIMES | 17 modified endowment contract (MEC) legislation (section ... be a target. 3 WHAT’S ON THE SHELF? … | FROM PAGE 17 END NOTES 1 The author would like to thank John ...- Authors: Brian King
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy