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IRS Notice Helps Government Money Market Funds Satisfy Diversification Rules
12. See also Webber v. Commissioner, 144 T.C. No. 17 (June 30, 2015); Christoff ersen v. United States ... 468. See also Webber v. Commissioner, 144 T.C. No. 17 (June 30, 2015). 8 “Insurance-dedicated” means that ...- Authors: John Adney, Bryan W Keene
- Date: Oct 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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To Clone or Not to Clone: The IRS Answers an Investor Control Question
deemed appropriate, FEBRUARY 2015 TAXING TIMES | 17 the QLAC was born. As amended in July 2014, the ... REGULATIONS PAVE THE WAY FOR “QLACs” | FROM PAGE 17 18 | TAXING TIMES FEBRUARY 2015 the industry continuing ...- Authors: John Adney
- Date: Feb 2015
- Publication Name: Taxing Times
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The Perils of Reducing Death Benefits: Private Letter Ruling 201230009
adjustment” for death benefit decreases under this rule.17 order not to disrupt sales of contracts. This ... | FROM PAGE 15 FEBRUARY 2013 TAXING TIMES | 17 however, since the application of the reasonable ...- Authors: John Adney, Craig R Springfield
- Date: Feb 2013
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Planning Ahead: Revenue Procedure Could Help Separate Accounts Comply with Section 817(h) When Investing in a New Type of Mortgage-Backed Securities
under that contract. FEBRUARY 2019 TAXING TIMES | 17 DETAIL ON THE NEW GUIDANCE Let’s look further at ... deemed to be issued by Fannie Mae and Freddie Mac;17 this ratio continues to apply thereafter to all ...- Authors: John Adney, Bryan W Keene
- Date: Mar 2019
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments; Pensions & Retirement
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IRS Rules on New BOLI Arrangement
generally applies to contracts issued after Aug. 17, 2006, subject to certain transition rules. Under ... does not apply to: a contract issued after [Aug. 17, 2006] pursuant to an ex- change described in section ...- 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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In the Beginning ... How Are Nonqualified Annuities Taxed?
discussed at length in prior TAXING TIMES articles.17 Exchanges, full and partial. Another beneficial ... case called Webber v. Commissioner, 144 T.C. No. 17 (2015), which describes how not to arrange one’s ...- Authors: John Adney
- Date: Mar 2016
- Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Annuities; Public Policy
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Cross-Border Life Insurance: Differing Definitions in an Age of International Tax Reporting
premium limi- tation” based on its death benefit,17 and that benefit at any time is at least a statutory ... value accumulation test.” 16 IRC section 7702(e)(1). 17 IRC section 7702(a)(2)(A) and (c). 18 IRC section ...- Authors: John Adney, Philip Friedlan
- Date: May 2014
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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Proposed Guidance on the New Net Investment Income Tax on “Annuities”
Frequently Asked Questions on section 1411 (“FAQs”).17 The FAQs address, among other topics, whether additional ... calculating “net gain” from dispositions of property. 17 See http://www.irs.gov/uac/Newsroom/Net-Invest ...- Authors: Alison R Peak, John Adney
- Date: May 2013
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Public Policy
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Accountant/Tax Attorney Dialogue: Part III
insurance contracts as life insurance contracts.17 Might there be circum- stances where the issuer of ... and distribution is MARCH 2016 TAXING TIMES | 17 identifying the person (or entity) that has the ...- Authors: Peter Winslow, Susan Hotine, John Adney, Mark Smith, Sheryl Flum
- Date: Mar 2016
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
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Life Settlements: Congress Wades Into the Fray
2009, however, this number dropped to $7.01 billion.17 According to a 2011 report, the U.S. life settlement ... curb STOlI). 16 See SEC RepoRt, supra note 6, at 3. 17 GAO RepoRt, supra note 8, at 8. 18 Fran matso lysiak ...- 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