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Taxing Times, September 2006, Volume 2, Issue No. 2
and in bringing their unique discipline to the table. Some may ask what you get when you bring a lawyer ... Insurance Tax Update and as such, brings to the table a tremendous amount of knowledge and experience ...- Authors: Barbara Gold, Brian King, Craig R Springfield, Peter Winslow, Samuel A Mitchell, Lori J Jones, Gregory Stephenson
- Date: Sep 2006
- Publication Name: Taxing Times
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Taxing Times - Tidbits
one-time electronic search of such poli- cies for U.S. indicia meeting the criteria outlined above. We ... Guidance Plan. 3 ers of life insurance and annuity contracts would be able to understand the tax ...- 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
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T3: Taxing Times Tidbits
a similar market-based approach to reserving in U.S. regulation of property/casualty companies and in ... amount of reserves required for its insurance and annuity contracts under the rules of any state in which ...- Authors: Peter Winslow, Emanuel Seth Burstein, Samuel A Mitchell, Lori J Jones, John Keenan
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting
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Change in Basis of Computing Reserves—Is It Or Isn’t It?
American General Life & Accident Insurance Co. v. U.S., 90-1 U.S.T.C. 50,010 (Mid. Dist. Tenn. 1989). 3 ... U.S.T.C. 9477 (D.C. Cir. 1975). 4 Diebold v. U.S., 16 Cl. Ct. 193, 63 A.F.T.R. 2d 89-599 (Cl. Ct.- Authors: Peter Winslow, Lori J Jones
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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New Developments for Life/Nonlife Consolidated Returns and the Disproportionate Asset Acquisition Rules
insur- ance reserves, assets and premiums of Lifeco 1’s business and whether it might cause Lifeco 1 to undergo ... Transaction, and, in the ordinary course of Lifeco 1’s busi- ness, is later amended or modified by Lifeco ...- Authors: Lori J Jones
- Date: May 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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IRS Proposes Separate Entity Treatment for a Cell
the taxable year is the issuing of insurance or annuity con- tracts or the reinsurance of risks underwritten ... its business was the issuing of insurance or annuity contracts or the reinsuring of risks underwritten ...- Authors: Lori J Jones, Janel C Frank
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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The Mystery of PLR 201006002
The Mystery of PLR 201006002 An explanation of the reasons why the IRS should rule on the ... transfer of a liability. Section 358(h) was enacted in 2000 in response to the “Son of Boss” transactions.- Authors: Julie V Goosman, Lori J Jones
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance
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Highlights of the Recent Guidance on Insurance Company Acquisitions
policy acquisition expens- es on life insurance and annuity contracts. The exist- ing rules in Treas. Reg. ... company’s reinsurance of liabilities under life, annuity and noncancellable acci- dent and health contracts ...- Authors: Lori J Jones
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>Actuarial methods in business operations
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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When Are Guaranty AssociationAssessments Deductible?
When Are Guaranty AssociationAssessments Deductible? Statutory Statement of Accounting Principle ... Company v. United States, 97 AFTR 2d 2006-1542 (U.S. Ct. Fed. Cl. 2006), the question came up as to whether ...- Authors: Peter Winslow, Lori J Jones
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
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A Practical Guide for Determining Whether a Section 338h10 Election Should Be Made for a Target Insurance Company
deemed liquidation of Old Target into its shareholder[s].4 The liquidation may be treated as tax-free pursuant ... interpretation of the regulation. P. Winslow and S. Mitchell, Valuation of Insurance in Force for Tax ...- Authors: Lori J Jones
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting