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T3: TAXING TIMES Tidbits
for arrange- ments entered into on or before Sept. 17, 2003, including Revenue Rulings 64-328 and 66-110 ... Many arrangements entered into on or before Sept. 17, 2003 took advantage of generous transition rules ...- Authors: Peter Winslow, Mark E Griffin, Susan Hotine, Lori Jones, Erinn Madden, Deborah Walker
- Date: Feb 2013
- Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Subchapter L: Can You Believe It?
interpretation of those factors should be considered.17 Unfortunately, we are not told how to determine ... at 366. 16 Technical Advice Memorandum 200448046. 17 See Joint Comm. Tax’n, JCS-41-84, General Explanation ...- Authors: Peter Winslow
- Date: Jun 2015
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
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Options for Inclusion of Stochastic Reserves
do permit company-specific assumptions to govern,17 as well as other statements in the legislative history ... H.R. Rep. No. 98-432, pt. 2, at 599–600 (1984). 17 E.g., I.R.C. § 807(d)(2)(C) permitting adjustments ...- Authors: Peter Winslow
- Date: Mar 2016
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
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Taxing Times - Tidbits
FEBrUarY 2012 TAXING TIMES | 43 CONTINUED ON PAGE 44 17 years later, the IRS has finally made public its ... FEBrUarY 2012 TAXING TIMES | 43 CONTINUED ON PAGE 44 17 years later, the IRS has finally made public its ...- Authors: Frederic Gelfond, Peter Winslow, Lori J Jones, Application Administrator
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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Actuary/Accountant/Tax Attorney Dialogue on Notice 2013-19 and the Statutory Reserves Cap
Actuary/Accountant/Tax Attorney Dialogue on Notice 2013-19 and the Statutory Reserves Cap Actuary/accountant/tax ... themselves. Stay tuned! OCTOBER 2013 TAXING TIMES | 17 END NOTES 1 2013-14 I.R.B. 743. 2 Notice ...- Authors: Edward Robbins, Mark Smith, Peter Winslow
- Date: Oct 2013
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
- Topics: Life Insurance>Reserves - Life Insurance; Public Policy
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SUBCHAPTER L: CAN YOU BELIEVE IT? DEDUCTIBLE TAX RESERVES MIGHT BE GREATER FOR LIFE INSURANCE CONTRACTS THAT FLUNK I.R.C. § 7702 THAN FOR THOSE THAT DO NOT
SUBCHAPTER L: CAN YOU BELIEVE IT? DEDUCTIBLE TAX RESERVES MIGHT BE GREATER FOR LIFE INSURANCE CONTRACTS THAT ... ON PAGE 18 OCTOBER 2015 TAXING TIMES | 17 John points out that as a prac- tical matter, ...- Authors: Peter Winslow, Susan Hotine
- Date: Oct 2015
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
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Taxing Times, May 2005, Volume 1, Issue No. 1
Taxing Times, May 2005, Volume 1, Issue No. 1 Full version of Taxing Times, May 2005, Volume 1, ... on QABs under IRC Sections 7702 and 7702A from pg. 17 18 4TAXING TIMES The well-known Canadian author ...- Authors: Application Administrator, Christian J DesRochers, Douglas N Hertz, Edward Robbins, Brian King, Craig R Springfield, Tom Quinn, Susan Hotine, Peter Winslow, Joseph F McKeever
- Date: May 2005
- Publication Name: Taxing Times