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  • XXX Reserve Funding is Debt for Federal Tax Purposes
    the purpose of distinguishing debt from equity.17 As described above, the analysis of whether surplus ... financial guaranty insurer. In an opinion dated Oct. 17, 2005, the Department’s Office of General Counsel ...

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    • Authors: Arthur C Schneider, Seth L Rosen
    • Date: Sep 2009
    • Competency: External Forces & Industry Knowledge
    • Publication Name: Taxing Times
    • Topics: Life Insurance>Reserves - Life Insurance; Public Policy
  • LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years
    LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years This article ... (GMxB) by Insurance Companies, LB&I-04-0514-0050 (July 17, 2014). See also Eric Bisighini & Tim Branch, Variable ...

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    • 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