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T3: TAXING TIMES TIDBITS
In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign ... parties changing the counterparty obligated to a domestic corporation (“Taxpayer”) under an existing agreement ...- 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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Taxing Times, May 2007, Volume 3, Issue No. 2
Taxing Times, May 2007, Volume 3, Issue No. 2 Full version of Taxing Times, May 2007, Volume ... Times, May 2007, Volume 3, Issue No. 2 Full version of Taxing Times, May 2007, Volume 3, Issue No. 2. 26420 ...- Authors: Application Administrator, Christian J DesRochers, Edward Robbins, Leslie Chapman, Brian King, Kory Olsen, Frederic Gelfond, Craig R Springfield, Bryan W Keene, Peter Winslow
- Date: May 2007
- Publication Name: Taxing Times
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Recent Guidance Involving the Taxation of Life Settlement Transactions
Guidance Involving the Taxation of Life Settlement Transactions A discussion of new IRS rulings with ... with respect to the taxation of life settlement transactions. Capital gains;Internal Revenue Service=IRS;Life ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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Fortuity, Or Not Fortuity … That Is the Question
Fortuity, Or Not Fortuity … That Is the Question Examines the Treasury Department and IRS guidance in ... arrangement qualifies as insurance under federal tax law. It concerns the concepts of fortuity, homogeneity, and ...- Authors: Frederic Gelfond
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Taxing Times Tidbits
discuss of notice and consent requirements for employer-owned life insurance policies and the IRS rules ... combination product. ;; Taxes=Taxation; Long-term care=LTC; Internal Revenue Service=IRS 4294992959 10/26/2012 ...- Authors: Frederic Gelfond, Brian King
- Date: Oct 2012
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Long-term Care
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Investor Control: Will You Know It When You See It?
See It? On June 30, 2015, the U.S. Tax Court reaffirmed the viability of the Investor Control Doctrine ... Commissioner. The case serves as a valuable example of what not to do with regard to the investment of assets ...- 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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IASB Exposure Draft on Insurance Contracts
Contracts Discusses the IASB insurance contract project and the major components of the new accounting standard ... standard, including the guidance it provides regarding how to define the term “insurance contract.” Accounting ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: May 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>International Accounting Standards Board [IASB]; Financial Reporting & Accounting>International Financial Reporting Standards [IFRS]
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Selected Insurance and International Tax Considerations for Investors in Life Settlement Businesses
This article is a discussion about the life settlement industry and the tax considerations for life insurance ... insurance bought and sold in the secondary market. Internal Revenue Service=IRS;Taxes=Taxation; 11557 ...- Authors: Frederic Gelfond
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance
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COLI Update - Court Decides Xcel Had Insurable Interest In Broad-Based COLI and Sixth Circuit Overturns Taxpayer-Favorable Decision in Dow Chemical COLI Case
products continue to be the focus of litigation by the IRS over the deductibility of policy loan interest ... Update consists of two articles concerning COLI cases and their most recent court decisions. The first concerns ...- Authors: Frederic Gelfond, Susan Hotine, Peter Winslow
- Date: May 2006
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; Technical Skills & Analytical Problem Solving>Innovative solutions
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Proposed Regulations Would Deny Reserve Deductions for Certain Captives
Proposed Regulations Would Deny Reserve Deductions for Certain Captives Discusses ... regarding reserve deductions for certain captives under IRC Section 1502 related to consolidated group intercompany ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting