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T3: TAXING TIMES TIDBITS
In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related ... would be substituted for and replace FC2 as the direct retrocessionaire under Retrocession 1, and FC1 ...- 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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Proposed Regulations Would Deny Reserve Deductions for Certain Captives
Proposed Regulations Would Deny Reserve Deductions for Certain Captives Discusses proposed ... regulations on intercompany transactions rather than a direct attack on captives themselves. Taxpayers currently ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Recent Guidance Involving the Taxation of Life Settlement Transactions
Premiums paid for a life insurance contract by a direct or indirect beneficiary under the contract are ... limitation on the deductibility of premiums by a direct or indirect beneficiary. CONTINUED ON PAGE 34 ...- Authors: Frederic Gelfond, Yvonne Fujimoto
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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FATCA and Insurance – Fundamental Questions Remain Unanswered as Compliance Deadline Approaches
There are some companies that enter into both direct insurance and reinsurance, but these are more ... the shoes of the ceding company and enters into a direct insur- ance relationship with the insured. It would ...- Authors: Frederic Gelfond, Mary Gillmarten
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Financial Reporting & Accounting
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IASB Exposure Draft on Insurance Contracts
IASB Exposure Draft on Insurance Contracts Discusses the IASB insurance contract project and ... which they reached different con- clusions. The primary area of tension between the IASB and IAsB ExPOsUrE ...- 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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Taxing Times - Tidbits
Taxing Times - Tidbits Issues covered in this article include 1. Tax treatment of advance ... exceeding $1,000,000; • Enable policyholders to direct how the assets will be in- vested, and such direction ...- Authors: Frederic Gelfond, Peter Winslow, Lori J Jones, Application Administrator
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy