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Protected Cell Series LLC Arrangements Should Consider Segregation Of Corporate Earnings And Liquidation Rights
Protected Cell Series LLC Arrangements Should Consider Segregation Of Corporate Earnings And Liquidation ... other cell or the protected cell company has a direct creditor claim against such cell); and Based ...- Authors: Lynlee C Baker
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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Recent Guidance Involving the Taxation of Life Settlement Transactions
Premiums paid for a life insurance contract by a direct or indirect beneficiary under the contract are ... limitation on the deductibility of premiums by a direct or indirect beneficiary. CONTINUED ON PAGE 34 ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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The Lingering Effects of the 2009 RMD Waiver
The Lingering Effects of the 2009 RMD Waiver A discussion of how issuers and providers of IRAs ... provided a similar clarification with respect to direct rollovers by nonspouse designated beneficiaries ...- Authors: Mark E Griffin, Joel Winston Mann
- Date: May 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Pensions & Retirement; Public Policy
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Canadian Taxation - Life Insurance
Canadian Taxation - Life Insurance As part of tax reform introduced effective at the beginning ... 869-1130. This is written in booklet form, the primary audience being accounting and tax practitioners ...- Authors: Society of Actuaries
- Date: Jun 1990
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Topics: Life Insurance; Public Policy
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Then and Now
Then and Now The author uses a reprint of an article from the very first edition of the “News ... Accountability Act • Accelerated Death Benefits, Long-Term Care, Modified Guaranteed Annuities • Eliminated ...- Authors: Paula Hodges
- Date: Oct 2013
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance>Pricing - Life Insurance; Life Insurance>Product development - 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)
as part of the Patient Protection and Affordable Care Act, and generally limits the deductibility of any ... purchased health insurance as a consequence of health care reform. The immediate con- cern for the life insurance ...- 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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Notice 2004-61: Guidance on Mortality under IRC Section 7702
Notice 2004-61: Guidance on Mortality under IRC Section 7702 Guidance and interpretation regarding ... made. However, Notice 2004-61 does not contain any direct statements identifying what such modifications ...- Authors: Application Administrator, Craig R Springfield
- Date: Mar 2005
- Competency: External Forces & Industry Knowledge
- Publication Name: Product Matters!
- Topics: Life Insurance; Public Policy
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Investment Risk and the Limits of Insurance
Investment Risk and the Limits of Insurance The Tidbit summarizes LTRs 201609008 and 201613016 ... may have influ- enced the IRS’ conclusions. The primary issue in the determination letters was whether ...- Authors: Patrick Tricker
- Date: Jun 2016
- Competency: Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Public Policy
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Inside the IRS: An Interview with William J. Wilkins
Inside the IRS: An Interview with William J. Wilkins An interview with William J. Wilkins, Chief Counsel ... Guidance on annuity contracts with a long- term care insurance feature under §§72 and 7702B. 10.- Authors: Christian J DesRochers
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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Legal Notes
Legal Notes This paper discusses the following cases: Rudolph V. United States- concerning ... Court distinguished between the attempt to create primary liability in this manner and waiver or estoppel ...- Authors: B. M. Anderson
- Date: Oct 1962
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Transactions of the SOA
- Topics: Public Policy; Public Policy