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The Demise of Sections 809 and 815
Comm. Print 1983) (“1983 Study”) (stating that “[s]tock life insurance companies, like other corporations ... capital to be paid out of after-tax earnings.”); S. REP. NO. 86-291, at 10-11 (1959) (“1959 Senate Report”) ...- Authors: William B Harman, Douglas N Hertz, Bryan W Keene
- Date: May 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Conseqeunces of Insurance Business or Company Acquisitions
the meaning of section 1504) as the seller or is an S corporation. A section 338(h)(10) election also requires ... ” The Insurance Tax Review (Sept. 2000), 19 Ins. Tax Rev. 375 (2000); and Gregory L. Stephenson, J. Howard ...- Authors: Gary Vogel, Kristie Khaw
- Date: Jun 2015
- Competency: Results-Oriented Solutions>Actionable recommendations; Technical Skills & Analytical Problem Solving>Innovative solutions; Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
- Topics: General Insurance (Property & Casualty); Life Insurance
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Guidance Released on COLI Best Practice Rules
for the transition rules governing section 101(j)’s application and for determining the insured’s status ... exchange, to base their mortality charge guarantees on the 2001 CSO mortality tables rather than the ...- Authors: Application Administrator, Bryan W Keene, Joel Winston Mann
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Whither the Definition of “Cash Surrender Value”—The IRS Issues More Waiver Rulings Discussing the Meaning of Section 7702f2A
being taken by the IRS. Taxation Section T I M E S VOLUME 5 | ISSUE 2 | MAY 2009 MAY 2009 TAXING ... Revenue Code of 1986, as amended (the “Code”). 3 S. PRT. No. 98-169, vol. I, at 573 (1984); H.R. REP ...- Authors: Application Administrator, Alison R Peak
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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New Closing Agreement Procedure for Failed Life Insurance Contracts—Rev. Proc. 2008-40
correction procedures relating to life insurance and annuity contracts, including those for addressing failures ... of the date of termination, or perhaps the rate(s) applicable since that date). Required representations ...- Authors: Craig R Springfield, Daniela Stoia
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance
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T3: TAXING TIMES Tidbits
at pwinslow@ scribnerhall.com. End Notes 1 See S. Mitchell, IRS Issues Exam Guidelines to Promote ... and (ii) covers the life of the owner’s employee(s) on the date the life insurance contract is issued ...- Authors: Peter Winslow, Lynlee C Baker
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Life Insurance
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From the Editor
From the Editor A look back on the 25th anniversary of the 1984 Tax Act DEFRA and newly proposed ... TAXING TIMES SEPTEMBER 2009 By Brian G. King T I M E S Facts and opinions contained herein are the sole ...- Authors: Brian King
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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History of the Use of Tax Rates in Sections 7702 and 7702A Closing Agreements
History of the Use of Tax Rates in Sections 7702 and 7702A Closing Agreements This article discusses ... “corridor” death benefits as required by section 7702’s minimum death benefit require- ment; and 4. Term ...- Authors: Brian King
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Rev. Proc. 2008-39—Correction of Inadvertent MECs: Is the Third Time the Charm?
addition, the Request must describe what “defect[s]” caused the inadvertent MECs’ failure to comply ... states that the Taxpayer agrees “[t]o bring Contract[s] for which the testing period (as defined in Sec ...- Authors: Craig R Springfield, Daniela Stoia
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance