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The Impact of BEAT on U.S.-Foreign Affiliated Reinsurance
The Impact of BEAT on U.S.-Foreign Affiliated Reinsurance Enacted pursuant to the 2017 Tax Cuts and ... (BEAT) is one of the most dramatic changes to the U.S. international tax landscape in recent years. The ...- Date: Dec 2020
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Reinsurance
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T3: TAXING TIMES TIDBITS
transaction between a foreign insurance company taxed as a U.S. company by virtue of an election under section 953(d) ... Taxpayer’s U.S. affiliates, that satisfied the criteria for treatment as annuity contracts. Taxpayer’s reinsurance ...- 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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T3: Taxing Times Tidbits
term life insurance contract. PLR 200919011—LTC-Annuity Rider In PLR 200919011, a life insurance company ... LTC insurance rider (the “Rider”) to a deferred annuity contract. For tax years after 2009, the Rider was ...- Authors: Mark E Griffin, Craig R Springfield, Daniela Stoia, Biruta P Kelly
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy; Reinsurance
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Assessing the Transfer of Risk: An Actuarial Perspective
premium life insur- ance policy and a nonrefund life annuity contract had eliminated any meaningful risk undertaking ... over all values where a deficit exists. In the table below, although both loss distributions have the ...- Authors: Christian J DesRochers
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments>Risk measurement - Finance & Investments; Finance & Investments>Value at risk - Finance & Investments; Reinsurance
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Insurance Transfer Pricing: Issues For Life Reinsurance Transactions
under comparable circumstances.8 In principle, the U.S. rules are very similar to the OECD Guidelines; ... deductions, or other items inappropriately among U.S. and foreign related persons,” and that “foreign ...- Authors: Christian J DesRochers
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance
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The Mystery of PLR 201006002
The Mystery of PLR 201006002 An explanation of the reasons why the IRS should rule on the ... transfer of a liability. Section 358(h) was enacted in 2000 in response to the “Son of Boss” transactions.- Authors: Julie V Goosman, Lori J Jones
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance