Description: The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works for purposes of the separate account dividends received deduction in the context of a partnership structure. The article explains the historical background of the proration formula as it appeared in the 1959 Act and the differences between how the applies and affects the dividends received deduction in the partnership structure versus the more tradition RIC structure.

Description: Description * This article summarizes Rev. Proc. 2018-54, in which the IRS provides for a new elective procedure that is intended to help segregated asset accounts and insurance-dedicated funds comply with the diversification requirements of Code section 817(h) with respect to investments in a new type of security known as a Uniform Mortgage-Backed Security.