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T3: Taxing Times Tidbits - What to do About Tax Reserve Estimates
T3: Taxing Times Tidbits - What to do About Tax Reserve Estimates We frequently are asked what ... an asset acquisition and COLI life insurance. Annuity reserves;Asset valuation;Beneficiaries;Internal ...- Authors: Susan Hotine, Peter Winslow, Samuel A Mitchell
- Date: Dec 2005
- 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
ending or borrowing in foreign currency subjects a U.S. company to foreign currency risk, which can be reduced ... synthetic U.S. dollar bond when it is integrated with an appropriate pay Euro/receive U.S. dol- lars ...- Authors: Peter Winslow, Emanuel Seth Burstein, Samuel A Mitchell, Biruta P Kelly
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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The Statutory Reserve Cap on TaxReserves Includes Deficiency Reserves
The Statutory Reserve Cap on TaxReserves Includes Deficiency Reserves Section 807d of the IRC ... calculated under prescribed interest rate and mortality assumptions, but in no event can the tax reserve ...- Authors: Peter Winslow, Samuel A Mitchell
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Life Insurance>Reserves - Life Insurance; Public Policy
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IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine
10 See I.r.C. § 7701(o)(1)(a) and (B). 11 293 U.s. 465, 469 (1935) (citations omitted). 12 See, e ... 10 See I.r.C. § 7701(o)(1)(a) and (B). 11 293 U.s. 465, 469 (1935) (citations omitted). 12 See, e ...- Authors: Samuel A Mitchell
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy