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IRS Provides Important Guidance on Changes in Basis of Computing Reserves under Section 807(f)
(“PBR”) methodologies for both life insurance and annuity contracts. Prior IRS guidance did not address specific ... made to section 807(d).[5] In fact, much of the IRS’s prior guidance predated the last major pre-TCJA change ...- Authors: Mark Smith
- Date: Mar 2021
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Public Policy
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Why Do Limitations Apply to Owners of Life Insurance Contracts, Particularly COLI?
Contracts, Particularly COLI? By Bryan W. Keene and Mark S. Smith It is well known that permanent, cash value ... on any life insurance policy, or endowment or annuity contract, if the taxpayer is directly or indirectly ...- 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
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New Regulations Provide Guidance on Computation and Reporting of Reserves
existing § 1.807-1, which provided guidance on mortality and morbidity tables to be used under pre-TCJA ... Valuation Manual, including CRVM and Commissioners’ Annuity Reserve Valuation Method (“CARVM”) reserves, which ...- 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
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IRS Applies Section 817(a) and (b) to a Nonlife Company: What Does It Mean?
IRS Applies Section 817(a) and (b) to a Nonlife Company: What Does It Mean? This article ... company that issues life insurance products taxes;annuity reserves;life reserves 6442456188 5/1/2014 12:00:00 ...- 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
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Overview of the Tax Cuts and Jobs Act: Major Changes
Insurers By James W. Kress, Surjya Mitra and Mark S. Smith On Dec. 22, 2017, President Trump signed into ... issued, reliance on prevailing interest rate and mortality tables, and application of a statutory reserves ...- 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
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Common Sense, Insurance in the Commonly Accepted Sense, and TAM 201149021
for tax purposes. The article questions the TAM's analysis and argues that the accounting regime applied ... applied produced a distortion in the insurer's income. 4294990360 5/1/2012 12:00:00 AM ...- 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
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Accountant/Tax Attorney Dialogue on the History and Purpose of Internal Revenue Code Section 811(a)
prescribed a tax method, interest rates and mortality tables, when applicable. But the committee reports ... prevailing interest rate, the prevailing mortality or morbidity table, as well as the elim- ination of any ...- 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
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IRS Chief Counsel Advice Addresses Interest Rate Election for Life Insurance Reserves
IRS Chief Counsel Advice Addresses Interest Rate Election for Life Insurance Reserves ... that were made and the impacts it has on a taxpayer's ability to make an election for determining the interest ...- Authors: Brien Alvino, Mark Smith
- Date: Feb 2020
- Competency: Results-Oriented Solutions
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting; Life Insurance; Life Insurance>Reserves - Life Insurance
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Accountant/Tax Attorney Dialogue: Part III
insurance classification and qualification under U.S. federal income tax law: examining the various characteristics ... the taxable year is the issuing of insurance or annuity contracts or the reinsuring Accountant/Tax Attorney ...- 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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Taxation Section Webcast: "Federal Income Tax Issues Every Company Must Consider under Life PBR"
Taxation Section Webcast: "Federal Income Tax Issues Every Company Must Consider ... under Life PBR.” Panelists Kristin R. Norberg, Mark S. Smith, and Peter H. Winslow led the audience through ...- Authors: Peter Winslow, Mark Smith, Kristin R Norberg
- Date: Oct 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance>Reserves - Life Insurance