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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 In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise ...- Authors: Samuel A Mitchell
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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Significant LB&I Examination Developments
Significant LB&I Examination Developments Article discusses recent changes in the IRS LB&I Division's examination practices and approach that may affect the work-flow of ...- Authors: Samuel A Mitchell
- Date: Oct 2016
- Competency: External Forces & Industry Knowledge>General business skills
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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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 to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of ...- 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
T3: Taxing Times Tidbits A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts. Asset valuation;Audits;Credit default swaps; ...- 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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IRS Issues Guidance on the Separate Account Dividends Received Deduction
IRS Issues Guidance on the Separate Account Dividends Received Deduction The article summarizes and comments on a recent IRS Chief Counsel Advice that addressed how the proration formula works ...- Authors: Samuel A Mitchell, John Adney
- Date: Jun 2016
- Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
- Publication Name: Taxing Times
- Topics: Annuities>Variable annuities; Enterprise Risk Management>Compliance; Finance & Investments>Investments; Financial Reporting & Accounting>Tax accounting
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LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years
LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years This article Provides a description of an IRS Directive that provides a safe harbor tax reporting position for computing ...- Authors: Samuel A Mitchell, Arthur C Schneider
- Date: Mar 2019
- Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities>Guaranteed living benefits; Life Insurance>Reserves - Life Insurance; Life Insurance>Secondary guarantees
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IRS Third-Party Summonses - Negotiated Cooperation Usually is the Best Approach
IRS Third-Party Summonses - Negotiated Cooperation Usually is the Best Approach A discussion of third-party summons, particularly those issued in promoter examinations. Satisfaction of the ...- Authors: Samuel A Mitchell
- Date: Oct 2012
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Actuarial Profession>Standards of practice
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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 provides that the deductible reserve for a life insurance contract is the greater of net surrender ...- 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 to Rule on the Meaning of Statutory Reserves
IRS to Rule on the Meaning of Statutory Reserves Discusses the meaning of statutory reserves with respect to a pending IRS ruling, in the case where different levels of statutory reserves are ...- 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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T3: Taxing Times Tidbits
T3: Taxing Times Tidbits Discusses five subjects, including proposed IASB discussion paper, split-dollar life insurance, penalties for paid tax preparers, statutory reserves for insurers, and ...- 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