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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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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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In the Beginning ... How Are Nonqualified Annuities Taxed?
discussed at length in prior TAXING TIMES articles.17 Exchanges, full and partial. Another beneficial ... case called Webber v. Commissioner, 144 T.C. No. 17 (2015), which describes how not to arrange one’s ...- Authors: John Adney
- Date: Mar 2016
- Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Annuities; Public Policy
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PLR 200906001 – A Conservative Taxpayer or a Very Subtle Message from the IRS?
of the insured of which the company is aware).”17 What is puzzling is what applicability the TAMRA ... under both sections 7702 and 7702A). 3 Oct. 17, 2008. A private letter ruling is issued to a particular ...- Authors: Daniela Stoia, Joseph F McKeever
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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T3: TAXING TIMES Tidbits
T3: TAXING TIMES Tidbits A discussion about premium deficiency reserves and tax regulations ... employer-owned life insurance contracts issued after Aug. 17, 2006, and the total amount of employer-owned life ...- 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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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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Cross-Border Life Insurance: Differing Definitions in an Age of International Tax Reporting
premium limi- tation” based on its death benefit,17 and that benefit at any time is at least a statutory ... value accumulation test.” 16 IRC section 7702(e)(1). 17 IRC section 7702(a)(2)(A) and (c). 18 IRC section ...- Authors: John Adney, Philip Friedlan
- Date: May 2014
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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The Road to the Remediation Revolution: A Short History of the Correction Procedures for Life Insurance and Annuity Contracts
whole.” After the issuance of Revenue Ruling 91-17, the Service saw an increase in waiver ruling requests ... correction programs announced in Revenue Ruling 91-17 and Revenue Procedure 92-25, analogized to ...- Authors: Application Administrator, Walter Welsh, Alison R Peak
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy
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Taxation Section Supplement, October 2014, Taxing Times
Products By Brion D. Graber and Peter H. Winslow 17 Sections 3504 and 3510: Computation of Insurance ... income to the basis of all assets of the company.17 The proposed disallowance formula is complicated ...- Authors: Society of Actuaries
- Date: Oct 2014
- Publication Name: Taxing Times
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ACLI Update
ACLI Update Update on a broad range of insurance and investment tax matters upon which ACLI ... Draft. FOREIGN ACCOUNT TAX COMPLIANCE ACT On Jan. 17, 2013, IRS and Treasury released “Final Regulations ...- Authors: Pete Bautz, Walter Welsh, Mandana Parsazad
- Date: May 2013
- Competency: Communication>Written communication
- Publication Name: Taxing Times
- Topics: Annuities; Financial Reporting & Accounting>Tax accounting; Life Insurance