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T3: TAXING TIMES TIDBITS
In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign ... foreign parties changing the counterparty obligated to a domestic corporation (“Taxpayer”) under an existing ...- Authors: Frederic Gelfond
- Date: Aug 2021
- Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Reinsurance; Reinsurance>General reinsurance
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IRS Updates Guidance on SEPP Exception to 10% Additional Tax
Exception to 10% Additional Tax This article discusses the guidance provided in IRS Notice 2022-6 and prior ... under a qualified retirement plan satisfy the exception to the 10 percent additional tax in Internal Revenue ...- Authors: Mark E Griffin, Prasanthi Paritala
- Date: Sep 2022
- Competency: Communication; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Pensions & Retirement>Defined contribution and 401k plans; Annuities>Deferred annuities
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LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years
Pre-TCJA Years This article Provides a description of an IRS Directive that provides a safe harbor tax ... Based Reserves methods. The safe harbor is required to be implemented on the 2017 tax return, with certain ...- Authors: Samuel A Mitchell, Arthur C Schneider
- Date: Mar 2019
- Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities>Guaranteed living benefits; Life Insurance>Reserves - Life Insurance; Life Insurance>Secondary guarantees
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A Conversation with Retired Company Tax Actuaries
Actuaries TAXING TIMES recently sat down with a group of retired tax actuaries to hear about how they got ... useful for actuaries who are just starting out in the profession, as well as more seasoned actuaries.- Authors: Mary Caramagno
- Date: Oct 2023
- Competency: Leadership; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting
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Treasury Issues Proposed Rules for Determining Active Income of Certain Foreign Insurance Companies
Income of Certain Foreign Insurance Companies This article briefly summarizes the history of the Passive ... provides a detailed description of the PFIC proposed regulations issued in July of 2019. Taxes=Taxation, Offshore ...- Authors: Jay Riback, Jean Baxley
- Date: Feb 2020
- Competency: Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments; Finance & Investments>Investments; Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting
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IRS’s Proposed LRD Rules for Nonlife Reserves are Out
IRS’s Proposed LRD Rules for Nonlife Reserves are Out A summary and analysis of REG-103163-18, ... Reserves are Out A summary and analysis of REG-103163-18, the proposed regulations providing guidance ...- Authors: Jay Riback
- Date: Mar 2019
- Competency: Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; General Insurance (Property & Casualty)>Reserves - General Insurance