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Surprising Investor Control Advice from IRS
account as- sets it holds in support of variable annuity and life insurance contracts it issues. The IRS ... those authorities the CCA Memo states only that “[u]nder Rev. Rul. 81-225, assets held directly by a ...- Authors: Bryan W Keene, Joseph F McKeever
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Life Insurance; Public Policy
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Update: IRS Issues Guidance Regarding the 2 Percent De Minimis Exception Under IRC Section 162(M)(6)
accounting principles” is intended to be a reference to U.S. GAAP or, given that the terms are not capitalized ... for example, under GAAP a $100 premium for an annuity contract is accounted for primarily as a deposit ...- Authors: Daniel Stringham
- Date: Oct 2013
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Generally Accepted Accounting Principles [GAAP]; Health & Disability>Health insurance; Public Policy
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Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements
that the owner of a variable life insurance or annuity contract who controls the selection and disposition ... (Oct. 10, 2014). 5 Skidmore v. Swi & Co., 323 U.S. 134, 140 (1944). 6 Sept. 14, 2016. 7 Oct. 27, ...- Authors: Bryan W Keene, John Adney
- Date: Jun 2017
- Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Individual annuities; Annuities>Investment strategy - Annuities; Annuities>Policyholder behavior - Annuities; Annuities>Variable annuities; Public Policy
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From the Editor – Different Viewpoints Increase Understanding
TAXING TIMES SEPTEMBER 2010 By Brian G. King T I M E S Facts and opinions contained herein are the sole ... regulation on the exchange of property for an annuity contract; guidance on the tax treatment of a partial ...- Authors: Brian King
- Date: Sep 2010
- Competency: Communication
- Publication Name: Taxing Times
- Topics: Actuarial Profession>Professional associations; Public Policy
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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 ...- 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
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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 ...- Authors: Christian J DesRochers, Benjamin J. Yahr
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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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 ...- 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
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From the Chair- Interesting Times
issue of TAXING TIMES, deal with 2017 changes to U.S. Tax Code and associated regulations. So putting ... each of the “big three” meetings—the Life and Annuity Symposium, the Valuation Actuary Symposium, and ...- Authors: Donald Walker
- Date: Jun 2017
- Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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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 ...- 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
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Many Hands Make Light Work
2013 FROM THE CHAIR MANy HANDS MAKE lIGHT WORK A s I was writing this article, we had just finalized ... perspectives on tax topics. Following the Life & Annuity Symposium in Toronto this spring, the Taxation ...- Authors: Mary Caramagno
- Date: Oct 2013
- Competency: Professional Values>Practice expertise; Relationship Management>Team leadership
- Publication Name: Taxing Times
- Topics: Actuarial Profession>Professional development; Financial Reporting & Accounting>Tax accounting; Public Policy