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From The Editor - In This Issue
TIMES FEBrUarY 2012 By Christian DesRochers T I m E s Published by the Taxation section Council of the ... unborrowed policy cash values on life insurance and annuity contracts. Under the proposal, the exception for ...- Authors: Christian J DesRochers
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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T3 – Taxing Times Tidbits
distributed. At the time of the transfer in December 2000, the policy had an account value of $1.368 million ... appropriate rate.’ See TAM 200038008 (June 13, 2000) and TAM 200339049 (Aug. 20, 2002).” Second, in ...- Authors: Christian J DesRochers, Susan Hotine, Peter Winslow
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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Tax Update
of the 2001 Commissioners’ Standard Ordinary Mortality Tables (the 2001 CSO Tables) in 2004 placed a ... Ruling 2009-14 presents three situations where a U.S. citizen purchases a life insurance contract and ...- Authors: Edward Robbins, Brian King
- Date: Nov 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Small Talk
- Topics: Financial Reporting & Accounting>Tax accounting
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A Few Thoughts About Tax Reform
A Few Thoughts About Tax Reform Discusses how the December 2017 US tax reform affects smaller ... using the minimum standards (state required mortality table, inter- est rate and method) as of the policy ...- Authors: Pamela Hutchins, Mark C Rowley
- Date: Feb 2018
- Competency: External Forces & Industry Knowledge
- Publication Name: Small Talk
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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ACLI Update
tax treatment of hedges relating to variable annuity contract guarantees. The American Council of ... ing of certain risks attributable to variable annuity contract guarantees. An ACLI letter dated Jan ...- Authors: Walter Welsh, Pete Bautz
- Date: May 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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Change in Basis of Computing Reserves—Is It Or Isn’t It?
American General Life & Accident Insurance Co. v. U.S., 90-1 U.S.T.C. 50,010 (Mid. Dist. Tenn. 1989). 3 ... U.S.T.C. 9477 (D.C. Cir. 1975). 4 Diebold v. U.S., 16 Cl. Ct. 193, 63 A.F.T.R. 2d 89-599 (Cl. Ct.- Authors: Peter Winslow, Lori J Jones
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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Guidance Needed to Clarify Allowance of Ordinary Losses Under Section 165g3 for Worthless Securities of Insurance Subsidiaries
in support of the argument that Rev. Rul. 88-65’s interpretation of section 165(g)(3) does or does ... ruling cites S. Rep. No. 91-1530, 91st Cong., 2d Sess. 2 (1970), 1971-1 C.B. 617, 618; S. Rep. No. 77-1631 ...- Authors: Maureen Nelson
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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New Developments for Life/Nonlife Consolidated Returns and the Disproportionate Asset Acquisition Rules
insur- ance reserves, assets and premiums of Lifeco 1’s business and whether it might cause Lifeco 1 to undergo ... Transaction, and, in the ordinary course of Lifeco 1’s busi- ness, is later amended or modified by Lifeco ...- Authors: Lori J Jones
- Date: May 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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What Does Textron Mean for Preserving the Confidentiality of Tax Accrual Workpapers?
workpapers. United States v. Arthur Young & Co., 465 U.S. 805 (1984). Nevertheless, the IRS has long recognized ... the Financial Accounting Standards Board (FASB)’s adoption of FIN 481, which requires corporations ...- Authors: Peter Winslow, Samuel A Mitchell
- Date: May 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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T3: Taxing Times Tidbits
Rev. Rul. 2011-1 requests comments on whether “annuity contracts and/or other tax-favored ac- counts held ... such as pooled separate accounts supporting annuity contracts that are treated as trusts under § 401(f) ...- Authors: Daniel Stringham, Peter Winslow, Joseph F McKeever
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Annuities>Variable annuities; Financial Reporting & Accounting>Tax accounting; Life Insurance