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  • Accountant/Tax Attorney Dialogue on the History and Purpose of Internal Revenue Code Section 811(a)
    sense operating similar to GAAP, statutory and IFRS financial accounting standards. That is, the determination ... In United Fire Insurance Company v. Commissioner,17 the Seventh Circuit, in rejecting the Service argument ...

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    • Authors: Richard N Bush, Arthur Schneider, Mark Smith, Peter Winslow
    • Date: Oct 2018
    • Competency: External Forces & Industry Knowledge>Actuarial theory in business context; External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Finance & Investments>Capital management - Finance & Investments; Finance & Investments>Risk measurement - Finance & Investments; Financial Reporting & Accounting>Financial Accounting Standards Board [FASB]; Financial Reporting & Accounting>Generally Accepted Accounting Principles [GAAP]; Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
  • IRS Applies Section 817(a) and (b) to a Nonlife Company: What Does It Mean?
    s.smith@ us.pwc.com. MAY 2014 TAXING TIMES | 17 CONTINUED ON PAGE 18 mechanical reading of section ... 817(a) AND (b) TO A NONLIFE COMPANY… | FROM PAGE 17 the temporary difference will reverse in three years ...

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    • Authors: Mark Smith, Charles Miller
    • Date: May 2014
    • Competency: Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Annuities>Reserves - Annuities; Annuities>Variable annuities; Financial Reporting & Accounting>Tax accounting; Life Insurance>Reserves - Life Insurance
  • Why Do Limitations Apply to Owners of Life Insurance Contracts, Particularly COLI?
    payment of a substantial number of future premiums.17 This definition presents interpretative questions ... applies to life insurance contracts issued after Aug. 17, 2006, except for a contract issued after that date ...

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    • Authors: Bryan W Keene, Mark Smith
    • Date: Jun 2019
    • Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Public Policy
  • 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 ...

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    • 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
  • Overview of the Tax Cuts and Jobs Act: Major Changes
    statutory reserves, with no cash surrender value floor.17 The life insurance company prora- tion provision ... 2017, H.R. 1628, 115th Cong., 1st Sess. (2017). 17 Chairman’s Mark, section 3703. 18 Chairman’s Mark ...

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    • Authors: Surjya Mitra, Mark Smith, James Kress
    • Date: Jun 2018
    • Competency: Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting
  • Session 139: Company Tax Hot Topics
    Session 139: Company Tax Hot Topics With the growth in SOA podcasts over recent years, here’s ... section 446 • What about sections 807(f) and 811(a)? 17 Why do the revenue procedures refer to section ...

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    • Authors: Thomas Chamberlain, Jay Riback, Mark Smith
    • Date: Feb 2020
    • Competency: External Forces & Industry Knowledge
    • Topics: Public Policy; Public Policy
  • Common Sense, Insurance in the Commonly Accepted Sense, and TAM 201149021
    recovery of basis before any income is recognized.17 The TAM presents the inverse. That is, gross income ... different issue and beyond the scope of this article. 17 The open transaction doctrine is generally applied ...

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    • Authors: Mark Smith, David A. Schenck, Surjya Mitra CPA
    • Date: May 2012
    • Competency: External Forces & Industry Knowledge>Actuarial theory in business context; External Forces & Industry Knowledge>General business skills
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
  • New Regulations Provide Guidance on Computation and Reporting of Reserves
    New Regulations Provide Guidance on Computation and Reporting of Reserves The article ... Conference Report at 479; see also Blue Book at 236-237. 17 P.L. 98-369. 18 85 Fed. Reg. 18502 (April 2, 2020) ...

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    • Authors: Mark Smith, Arthur Schneider
    • Date: Nov 2020
    • Competency: Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Life Insurance; Life Insurance>Reserves - Life Insurance
  • Actuary/Accountant/Tax Attorney Dialogue on Notice 2013-19 and the Statutory Reserves Cap
    Actuary/Accountant/Tax Attorney Dialogue on Notice 2013-19 and the Statutory Reserves Cap Actuary/accountant/tax ... themselves. Stay tuned! OCTOBER 2013 TAXING TIMES | 17 END NOTES 1 2013-14 I.R.B. 743. 2 Notice ...

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    • Authors: Edward Robbins, Mark Smith, Peter Winslow
    • Date: Oct 2013
    • Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; Technical Skills & Analytical Problem Solving>Problem analysis and definition
    • Publication Name: Taxing Times
    • Topics: Life Insurance>Reserves - Life Insurance; Public Policy
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