Description: October issue of Taxing Times

Description: The rules governing the tax treatment of distributions from life insurance or annuity contracts are complex. Worse, the relevant IRC section, section 72, seems at times to be the product of a conspiracy in restraint of understanding.

Description: This article is a discussion about automatic waivers and the corresponding procedures under IRC sections 7702 and 101f.

Description: The Internal Revenue Service issued its seminal ruling interpreting Internal Revenal Code section 7702A[c][3][B][i], commonly referred to as the Necessary Premium Test [NPT]. The purpose of the NPT is to shelter certain death benefit increases from material change status, avoiding the 7 pay test's reapplication on their account.

Description: Provides in-depth discussion of IRS Rev. Proc. 2008-24, including tax background of partial annuity exchanges. Then discusses partial annuitizations and “modified endowment contracts.”

Description: Comparison of statutory and tax accounting rules in treatment of non-performing assets.

Description: On July 14, 2005, the FASB issued an Exposure Draft of a proposed Interpretation, Accounting for Uncertain Tax Positions—an Interpretation of FASB Statement No. 109. If adopted, the proposed Interpretation is the most significant tax accounting guidance the FASB has issued since FASB Statement No. 109 “Accounting for Income Taxes,” FAS 109 in 1992.

Description: This article highlights the achievements and successes of the section in 2008.

Description: This editorial highlights the hot topics happening in the tax industry today.

Description: Our third issue of Taxing Times arrives just as 2005 is coming to an end. Reflecting back on this past year, I am amazed and pleased with how much the Taxation Section has accomplished.