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IRS Applies Section 817(a) and (b) to a Nonlife Company: What Does It Mean?
IRS Applies Section 817(a) and (b) to a Nonlife Company: What Does It Mean? This article discusses ... a recently-issued Chief Counsel Advice in which the IRS applied a life insurance company tax rule to ...- Authors: Mark Smith, Charles Miller
- Date: May 2014
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Annuities>Reserves - Annuities; Annuities>Variable annuities; Financial Reporting & Accounting>Tax accounting; Life Insurance>Reserves - Life Insurance
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IRS Issues Guidance on the Separate Account Dividends Received Deduction
IRS Issues Guidance on the Separate Account Dividends Received Deduction The article summarizes and ... Advice that addressed how the proration formula works for purposes of the separate account dividends ...- Authors: Samuel A Mitchell, John Adney
- Date: Jun 2016
- Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Enterprise Risk Management>Compliance; Finance & Investments>Investments; Financial Reporting & Accounting>Tax accounting
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Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements
Fund of Funds Arrangements The article summarizes several recent private letter rulings from the IRS ... IRS addressing the "investor control" doctrine in the context of funds of funds. Annuities;Asset ...- 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