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  • Rev. Proc. 2019-10: New Guidance on Changes in the Basis of Determining Life Insurance Reserves
    Rev. Proc. 2019-10: New Guidance on Changes in the Basis of Determining Life Insurance Reserves ... as outlined in Revenue Procedure 2019-10, the IRS’s December 2018 guidance on the subject, and discusses ...

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    • Authors: Robert M Nelson, Sheryl Flum
    • Date: Jun 2019
    • Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Actuarial Profession; Actuarial Profession>Competencies; Actuarial Profession>Professional development; Actuarial Profession>Traditional careers; Life Insurance
  • COLI Update - Court Decides Xcel Had Insurable Interest In Broad-Based COLI and Sixth Circuit Overturns Taxpayer-Favorable Decision in Dow Chemical COLI Case
    COLI Update - Court Decides Xcel Had Insurable Interest In Broad-Based COLI and Sixth Circuit ... court decisions. The first concerns a District Court’s ruling on insurable interest, and the second provides ...

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    • Authors: Frederic Gelfond, Susan Hotine, Peter Winslow
    • Date: May 2006
    • Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; Technical Skills & Analytical Problem Solving>Innovative solutions
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy
  • Revenue Ruling 2005-6: Guidanceon QABs under IRS Sections 7702and 7702A
    section 7702(c)(3)(B)(ii), and not the “reasonable mortality charge rule” of section 7702(c)(3)(B)(i), for ... rules regarding the assumptions with respect to mortality and expense charges that must be used in determining ...

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    • Authors: Application Administrator, Craig R Springfield, Joseph F McKeever
    • Date: May 2005
    • Competency: Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy
  • I-COLI: The Genesis of Revenue Procedure 2007-61 and the Future of Insurer-Owned Life Insurance
    that they apply to “life insurance policies and annuity and endowment contracts to which section 264(f) ... denied, 540 U.S. 1104 (2004); In re C.M. Holdings, Inc., 254 B.R. 578 (D. Del. 2000), aff’d 301 F.3d ...

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    • Authors: Application Administrator, Michelle Antoinette Garcia, Kirk Van Brunt
    • Date: Feb 2008
    • Competency: External Forces & Industry Knowledge
    • Publication Name: Taxing Times
    • Topics: Life Insurance
  • The Interaction of Section 7702 and the Nonforfeiture Law - Trouble Ahead for Traditional Life Insurance
    INsUraNCE? By Benjamin J. Yahr and Christian DesRochers S ection 7702 imposes two requirements that a contract ... section 7702 was enacted. Standards limiting the mortality and interest assumptions per- mitted in computation ...

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    • Authors: Christian J DesRochers, Benjamin J. Yahr
    • Date: Feb 2012
    • Competency: External Forces & Industry Knowledge
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy
  • Final Regs on Discounting Cancellable A&H (and Property-Casualty) Claim Reserves Under § 846
    below-market loans under section 1274(d), derived from U.S. obligations with maturities over three but not ... A taxpayer could either • file an amended return(s) using the revised factors, or • calculate the adjustment ...

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    • Authors: Gregory K Oyler
    • Date: Nov 2019
    • Competency: Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: General Insurance (Property & Casualty); General Insurance (Property & Casualty)>Reserves - General Insurance; Life Insurance; Life Insurance>Reserves - Life Insurance
  • Private Rulings Regarding“Cash Surrender Value”Under Section 7702
    Skipper, Jr., Life & Health Insurance 46 (13th ed. 2000) (“Black & Skipper”). Another cited text defined ... surrender value as “[t]he amount of prefunded mortality charges that is available to a terminating policyowner ...

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    • Authors: Brian King, Craig R Springfield
    • Date: Sep 2006
    • Competency: External Forces & Industry Knowledge>External forces and business performance
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy
  • Final Regulations Under Sections 101 and 6050Y
    respect to a con- tract is a gratuitous transfer to a U.S. person:9 • The preamble notes that the acquirer ... Reporting by Issuers (Forms 1099-SB, 1099-R, and 1042-S) There were also a number of clarifying changes made ...

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    • Authors: Craig R Springfield, Kristin R Norberg
    • Date: Feb 2020
    • Competency: Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy
  • Getting to Know Walter Welsh
    Springfield ________________ 8 NAIC Proposal for Mortality Under Pre-Need Life Insurance by John T. Adney ... developing new forms of benefits in life insurance and annuity con- tracts, including new forms of long-term care ...

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    • Authors: Society of Actuaries
    • Date: May 2008
    • Competency: External Forces & Industry Knowledge>External forces and business performance
    • Publication Name: Taxing Times
    • Topics: Life Insurance
  • Determining the Value of a LifeInsurance Contract: RevenueProcedure 2005-25
    under which the plan assets are life insurance or annuity contracts. Of particular interest to the IRS was ... minus • Reasonable mortality charges and reasonable charges (other than mortality charges), but only ...

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    • Authors: Christian J DesRochers
    • Date: Dec 2005
    • Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy