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Planning Ahead: Revenue Procedure Could Help Separate Accounts Comply with Section 817(h) When Investing in a New Type of Mortgage-Backed Securities
under that contract. FEBRUARY 2019 TAXING TIMES | 17 DETAIL ON THE NEW GUIDANCE Let’s look further at ... deemed to be issued by Fannie Mae and Freddie Mac;17 this ratio continues to apply thereafter to all ...- Authors: John Adney, Bryan W Keene
- Date: Mar 2019
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments; Pensions & Retirement
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IRS Proposes Separate Entity Treatment for a Cell
IRS Proposes ... Issue 1 FEBRUARY 2011 TAXING TIMES | 17 IRS PROPOSES SEPARATE ENTITY TREATMENT FOR A ... CONTINUED ON PAGE 18 IRS PROPOSES … | FROM PAGE 17 18 | TAXING TIMES FEBRUARY 2011 of the proposed ...- Authors: Lori J Jones, Janel C Frank
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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To Clone or Not to Clone: The IRS Answers an Investor Control Question
deemed appropriate, FEBRUARY 2015 TAXING TIMES | 17 the QLAC was born. As amended in July 2014, the ... REGULATIONS PAVE THE WAY FOR “QLACs” | FROM PAGE 17 18 | TAXING TIMES FEBRUARY 2015 the industry continuing ...- Authors: John Adney
- Date: Feb 2015
- Publication Name: Taxing Times
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New Closing Agreement Procedure for Failed Life Insurance Contracts—Rev. Proc. 2008-40
Prior closing agreement procedures. In Rev. Rul. 91-17, the Service announced that for a limited period ... are similar to those set forth in Rev. Rul. 91-17, although a number of changes have been instituted ...- 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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Determining the Value of a LifeInsurance Contract: RevenueProcedure 2005-25
Determining ... Positions Matthew M. Haaf and Ernest C. Achtien 17 Experience Rating, Helvering vs. Le Gierse, and ... 1989-1 C.B. 622, Question 10. 13 REG-126967-03, 2/17/04. 14 I.R.B. 2004-10. 446continued ...- 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
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IRS Provides Relief for Late Rollovers with New Self-Certificate
rollovers. With the publication of Rev. Proc. 2016-17, however, the IRS showed its intent was not to cre- ... the mental condition or incapacity of the taxpayer,17 or the erroneous advice of a financial advisor not ...- Authors: Michael Byro
- Date: Feb 2017
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
- Topics: Public Policy
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Uncertainty Remains in Tax Reserve Assumptions for Guaranteed Renewable and Noncancellable Health Insurance
Rules on American Financial By Richard N. Bush 17 Tapping a New Revenue Source— Congress Expands the ... change in method of accounting otherwise would occur.17 Usually, changes in assumptions in life insurance ...- Authors: Edward Robbins, Peter Winslow
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Health & Disability; Public Policy
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Conseqeunces of Insurance Business or Company Acquisitions
amortization regime for “section 197 intangibles.”17 If the reinsured contracts are subject to section ... $50, individual life insurance contracts worth $17, liabilities (tax reserves) of $50, and $20 of general ...- 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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On Grandfathers and Adjustments: New IRS Chief Counsel Advice Memo Blurs Lines
Chief Counsel Advice Memorandum 200805022 (Aug. 17, 2007) (the “CCA”), the Service essentially concludes ... “materially changed” on or after a certain date.17 The Service acknowledged that the TAMRA conference ...- Authors: Application Administrator, Craig R Springfield
- Date: May 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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The Open Transaction Doctrine Applies to the Sale of Stock of a Demutualized Life Insurer in Fisher, But Should It?
considerable merit. … MAY 2010 TAXING TIMES | 17 CONTINUED ON PAGE 18 In the landmark case of Burnet ... 3 THE OPEN TRANSACTION DOCTRINE … | FROM PAGE 17 Emanuel Burstein is the author of Federal Income ...- Authors: Emanuel Burnstein
- Date: May 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy