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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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Federal Income Tax Accounting - United States
TAX ACCOUNTING - UNITED STATES Moderator: LOUISE S. GOLDMAN Panelists: CHARLES D. FRIEDSTAT PATRICIA ... value of the subsidiary and what's on the subsidiary 's books would be the mandatory securities valuation ...- Authors: Charles D Friedstat, Louise Goldman, Patricia Guinn, John Joseph Rutter, Louis Weisz, Charlie T Whitley
- Date: May 1985
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Record of the Society of Actuaries
- Topics: 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
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Canadian Income Tax
Canadian Income Tax This panel discusses Canadian income tax. From Transactions of Society of ... be taxed on its Canadian business D260 DISCUS S IONmCONCURRENT SESSIONS only. I t would be inconsistent ...- Authors: William H Burling, H Edward Harland, J Craig Davidson, George C Campbell
- Date: Oct 1969
- Competency: External Forces & Industry Knowledge
- Publication Name: Transactions of the SOA
- Topics: Financial Reporting & Accounting>Tax accounting