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Guidance Released on COLI Best Practice Rules
4) is issued or “materially changed” after Aug. 17, 2006. An applicable policyholder is a person who ... rules apply only to contracts “issued” after Aug. 17, 2006, and because the notice and con- sent requirements ...- Authors: Application Administrator, Bryan W Keene, Joel Winston Mann
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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The Interaction of Section 7702 and the Nonforfeiture Law - Trouble Ahead for Traditional Life Insurance
TIMES FEBrUarY 2012 FEBrUarY 2012 TAXING TIMES | 17 CONTINUED ON PAGE 18 ThE INTEraCTION OF sECTION ... TIMES FEBrUarY 2012 FEBrUarY 2012 TAXING TIMES | 17 CONTINUED ON PAGE 18 ThE INTEraCTION OF sECTION ...- Authors: Christian J DesRochers, Benjamin J. Yahr
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Determining the Value of a LifeInsurance Contract: RevenueProcedure 2005-25
Determining ... Positions Matthew M. Haaf and Ernest C. Achtien 17 Experience Rating, Helvering vs. Le Gierse, and ... 1989-1 C.B. 622, Question 10. 13 REG-126967-03, 2/17/04. 14 I.R.B. 2004-10. 446continued ...- Authors: Christian J DesRochers
- Date: Dec 2005
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
- Topics: Life Insurance; 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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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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T3: Taxing Times Tidbits
See, e.g., PLR 200339015 (June 17, 2003) and PLR 200339016 (June 17, 2003), both involving critical ... 2 2008-29 I.R.B. 160, amplifying Rev. Rul. 91-17, 1991-1 C.B. 190. Rev. Proc. 2008-42 provides the ...- 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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What’s on the Shelf? A Proposal to Tax the Inside Buildup
| FROM PAGE 15 SEPTEMBER 2009 TAXING TIMES | 17 modified endowment contract (MEC) legislation (section ... be a target. 3 WHAT’S ON THE SHELF? … | FROM PAGE 17 END NOTES 1 The author would like to thank John ...- Authors: Brian King
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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The Demise of Sections 809 and 815
REVIEW 31 (January 2001). MAY 2006 327 industry.17 Moreover, the enactment of the Gramm- Leach-Bliley ... Will Congress turn to these provisions next? 3 17 In 2003, stock life insurance companies held approximately ...- Authors: William B Harman, Douglas N Hertz, Bryan W Keene
- Date: May 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Investor Control: Will You Know It When You See It?
control rules, Inv. An- nuity, Inc. v. Blumenthal,17 was dismissed by the appellate court due to lack ... Revenue Code of 1986, as amended. 4 144 T.C. No. 17 (June 30, 2015). 5 2003-2 C.B. 347. 6 309 U.S ...- Authors: Ann Cammack, Frederic Gelfond
- Date: Mar 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Rev. Proc. 2008-41—Correction of Inadvertent Diversification Failures
is limited to inadvertent diversification errors.17 In the authors’ experience, establishing inadvertence ... Id. at 41,652. 16 T.D. 9385, 2008-15 I.R.B. 735. 17 Treas. Reg. § 1.817-5(a)(2)(i) and Rev. Proc. 2008-41 ...- Authors: Bryan W Keene, Joseph F McKeever
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Life Insurance; Public Policy