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IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine
IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine ... an effort to raise revenue as part of the health care reform legislation.1 The law provides for strict ...- Authors: Samuel A Mitchell
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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T3: Taxing Times Tidbits
premium reserve” in the New York Insurance Law. The primary purpose of the unearned premium re- serve was to ... the standard of care required of the return preparer is greater than the standard of care required of the ...- 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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T3: Taxing Times Tidbits
The tax is four percent of premiums paid for direct insurance of U.S. property/casualty risks or one ... outside auditors’ workpapers probably will be the primary focus of FIN 48 workpaper disputes. As of now ...- 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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What Does Textron Mean for Preserving the Confidentiality of Tax Accrual Workpapers?
generally applies to legal advice prepared for the primary purpose of aid- ing in anticipation of future litigation ... anticipation of litigation.” Some courts apply a primary purpose test. For example, the Fifth Circuit has ...- Authors: Peter Winslow, Samuel A Mitchell
- Date: May 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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IRS to Rule on the Meaning of Statutory Reserves
IRS to Rule on the Meaning of Statutory Reserves Discusses the meaning of statutory reserves ... contrary to the IRS representatives’ assumption, the primary goal of Congress in enacting I.R.C. § 807 was ...- Authors: Peter Winslow, Samuel A Mitchell
- Date: Feb 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
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Insurance Company Bad Debt
Insurance Company Bad Debt Discusses some of the issues the IRS and insurance companies ... underlying the Revenue Ruling makes it clear that the primary reason the IRS held that the conclusive presumption ...- Authors: Samuel A Mitchell
- Date: Sep 2011
- Competency: External Forces & Industry Knowledge
- Topics: Financial Reporting & Accounting>Tax accounting