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Accountant/Tax Attorney Dialogue: Part III
insurance classification and qualification under U.S. federal income tax law: examining the various characteristics ... the taxable year is the issuing of insurance or annuity contracts or the reinsuring Accountant/Tax Attorney ...- Authors: Peter Winslow, Susan Hotine, John Adney, Mark Smith, Sheryl Flum
- Date: Mar 2016
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
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IRS Rules on New BOLI Arrangement
IRS Rules on New BOLI Arrangement This article discusses the ruling on the new BOLI arrangement ... the tax treatment of the arrangement: (1) the LLC’s taxation as a partnership as opposed to an investment ...- Authors: John Adney, Bryan W Keene
- Date: May 2012
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements
that the owner of a variable life insurance or annuity contract who controls the selection and disposition ... (Oct. 10, 2014). 5 Skidmore v. Swi & Co., 323 U.S. 134, 140 (1944). 6 Sept. 14, 2016. 7 Oct. 27, ...- Authors: Bryan W Keene, John Adney
- Date: Jun 2017
- Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Individual annuities; Annuities>Investment strategy - Annuities; Annuities>Policyholder behavior - Annuities; Annuities>Variable annuities; Public Policy
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Planning Ahead: Revenue Procedure Could Help Separate Accounts Comply with Section 817(h) When Investing in a New Type of Mortgage-Backed Securities
separate accounts supporting nonqualified variable annuity and life insurance contracts, the statute was ... was amended in 1988 to make clear that each U.S. government agency or instrumental- ity was to be treated ...- Authors: John Adney, Bryan W Keene
- Date: Mar 2019
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments; Pensions & Retirement
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IRS Updates Post-Age-100 Guidance
(1) have mortality guarantees based on the 2001 Commissioners’ Standard Ordinary Mortality Tables (2001 ... rules to “life insurance contracts that have mortality guarantees based upon not only the 2001 CSO tables ...- Authors: John Adney
- Date: Jun 2018
- Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance>Product development - Life Insurance
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What Are the Sources of the Federal Tax Law?
seventh or eighth grade civics class, that under the U.S. Constitution federal laws emanate from acts of ... working in conjunction with officials of the U.S. Treasury Department under grants of authority from ...- Authors: John Adney
- Date: May 2014
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting; Public Policy
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IRS Notice Helps Government Money Market Funds Satisfy Diversification Rules
supporting nonqualified variable life insur- ance and annuity contracts. The purpose of both the statute and ... government securities.” Variable life insurance and annuity contracts, of course, may be based on segregated ...- Authors: John Adney, Bryan W Keene
- Date: Oct 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting