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Accountant/Tax Attorney Dialogue: Part III
relating to life insurance, annuities, long-term care insurance and accel- erated death benefits.3 In ... prior law except that, instead of looking to the primary and predominant business activity, it re- quires ...- 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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The Second Edition of Life Insurance & Modified Endowments Under Internal Revenue Code Sections 7702 and 7702A
limitations imposed and opportunities presented by the primary and alternate computational rules, considerations ... treatment of addi- tional term insurance covering the primary life insured under a contract. The mysteries ...- 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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In the Beginning ... How Are Nonqualified Annuities Taxed?
individual, the statute’s rules apply as if the “primary annuitant” were the owner, and if the annui- tant ... investment income tax” imposed by the 2010 health care legislation. The tax under section 1411 applies ...- 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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Product Tax Implications of the Adoption of the 2017 CSO
certain ter- ritories) representing 75 percent of direct written premium, the Valuation Manual is now scheduled ... environment (since this test does not impose any direct limitation on premiums). However, universal life ...- Authors: Brian King, John Adney, Craig R Springfield
- Date: Oct 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements
the contract owner may be indirect as well as direct. For example, the ability to allocate policy values ... the Portfolio and the inability of an owner to direct investment in a particular asset or to recommend ...- Authors: Bryan W Keene, John Adney
- Date: Jun 2017
- Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Individual annuities; Annuities>Investment strategy - Annuities; Annuities>Policyholder behavior - Annuities; Annuities>Variable annuities; Public Policy
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IRS Releases New Ruling on BOLI Partnership
individual partners, each of whom is deemed to own a direct undivided interest in partnership assets and operations ... such that the partners are not deemed to have a direct interest in partnership assets or operations, ...- Authors: Bryan W Keene, John Adney
- Date: May 2013
- Competency: Professional Values
- Publication Name: Taxing Times
- Topics: Life Insurance
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Proposed Guidance on the New Net Investment Income Tax on “Annuities”
INCOME TAX ON “ANNUITIES” A s part of the health care legislation enacted in March of 2010, Congress added ... insurance contracts. BACKGROUND & HISTORY The Health Care and Education Reconciliation Act of 2010 added section ...- 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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They Go Bump in the Night: Life Insurance Policies and the Law of Material Change
seemingly Congress would have provided some more direct indication to this effect in the stat- ute or legislative ... section 264(f) transition rule is unclear, and care especially should be exercised in any case where ...- 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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IRS Notice Helps Government Money Market Funds Satisfy Diversification Rules
IRS Notice Helps Government Money Market Funds Satisfy Diversification Rules This article ... control” was likely intended to mean no actual, direct control over the government MMF’s investment activity ...- 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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The Perils of Reducing Death Benefits: Private Letter Ruling 201230009
coverage is being decreased. Instead, what they care about is whether they will be able to make a change ... section 7702B, which defines “qualified long-term care insurance contract,” provided that reductions in ...- Authors: John Adney, Craig R Springfield
- Date: Feb 2013
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting