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IRS Rules on New BOLI Arrangement
IRS Rules on New BOLI Arrangement This article discusses the ruling on the new BOLI arrangement and addresses three aspects of the tax treatment of the arrangement: (1) the LLC’s taxation as a ...- Authors: John Adney, Bryan W Keene
- Date: May 2012
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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IRS Notice 2016-63 – Safe Harbor Guidance for 2017 CSO
IRS Notice 2016-63 – Safe Harbor Guidance for 2017 CSO The article addresses the safe harbor guidance provided in Notice 2016-63 for 2017 CSO contracts satisfying the section 7702 reasonable ...- Authors: Brian King, John Adney, Craig R Springfield
- Date: Feb 2017
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Enterprise Risk Management>Compliance; Life Insurance>Product development - Life Insurance; Public Policy
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IRS Issues Guidance on the Separate Account Dividends Received Deduction
IRS Issues Guidance on the Separate Account Dividends Received Deduction The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works ...- Authors: Samuel A Mitchell, John Adney
- Date: Jun 2016
- Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Enterprise Risk Management>Compliance; Finance & Investments>Investments; Financial Reporting & Accounting>Tax accounting
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Possible Opportunities for Product Design: the IRS Advises on a Notice That Does Not Apply to Non-Qualified Annuities
Possible Opportunities for Product Design: the IRS Advises on a Notice That Does Not Apply to Non-Qualified Annuities Examines Notice 2016-39 on phased retirement payments from defined benefit ...- Authors: John Adney, Mark E Griffin
- Date: Oct 2016
- Competency: Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Payout annuities
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Cross-Border Life Insurance: Differing Definitions in an Age of International Tax Reporting
Cross-Border Life Insurance: Differing Definitions in an Age of International Tax Reporting The article discussing the differing tax definitions of life insurance in the US and Canada and relates ...- Authors: John Adney, Philip Friedlan
- Date: May 2014
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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In the Beginning… A Column Devoted to Tax Basics Premiums Paid, Investment in the Contract, and Tax Basis – We Know
In the Beginning… A Column Devoted to Tax Basics Premiums Paid, Investment in the Contract, and Tax Basis – We Know Basic discussion of premiums paid, investment in the contract, and basis as ...- Authors: John Adney
- Date: Jun 2017
- Competency: External Forces & Industry Knowledge>External forces and business performance; Results-Oriented Solutions>Actionable recommendations
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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The Second Edition of Life Insurance & Modified Endowments Under Internal Revenue Code Sections 7702 and 7702A
The Second Edition of Life Insurance & Modified Endowments Under Internal Revenue Code Sections 7702 and 7702A Overview of upcoming second edition of book. Tax accounting;Tax accounting ...- Authors: John Adney, Brian King, Craig R Springfield
- Date: Jun 2015
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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They Go Bump in the Night: Life Insurance Policies and the Law of Material Change
They Go Bump in the Night: Life Insurance Policies and the Law of Material Change The different broad purposes served by the material change concept under federal tax law are outlined. More ...- Authors: John Adney, Craig R Springfield
- Date: May 2012
- Competency: External Forces & Industry Knowledge>Actuarial theory in business context; Strategic Insight and Integration>Effective decision-making
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance>Policyholder behavior - Life Insurance
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Life Settlements: Congress Wades Into the Fray
Life Settlements: Congress Wades Into the Fray Article examines a proposed amendment to the MAP-21 Act that would have changed a number of tax requirements regarding so-called life settlements.- Authors: John Adney, Bryan W Keene
- Date: Oct 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Health & Disability; Life Insurance; Public Policy
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To Clone or Not to Clone: The IRS Answers an Investor Control Question
To Clone or Not to Clone: The IRS Answers an Investor Control Question The article discusses a recent IRS private ruling on the application of the investor control doctrine to a variable contract ...- Authors: John Adney
- Date: Feb 2015
- Publication Name: Taxing Times