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  • 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
  • Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements
    Recent IRS Rulings Highlight Investor Control Issues for Fund of Funds Arrangements The article ... “clone” funds, i.e., JUNE 2017 TAXING TIMES | 17 nonetheless suggest a concern, at least by the taxpayers ...

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    • Authors: Bryan W Keene, John Adney
    • Date: Jun 2017
    • Competency: Professional Values>Practice expertise; Strategic Insight and Integration>Strategy development
    • Publication Name: Taxing Times
    • Topics: Annuities>Individual annuities; Annuities>Investment strategy - Annuities; Annuities>Policyholder behavior - Annuities; Annuities>Variable annuities; Public Policy
  • IRS Issues Guidance on the Separate Account Dividends Received Deduction
    IRS Issues Guidance on the Separate Account Dividends Received Deduction The article summarizes and ... been thwarted. ■ ENDNOTES 1 CCA 201603023 (July 17, 2015) (Released to the public on Jan. 15, 2016) ...

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    • 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
  • Dynamic Assumption-Setting for Variable and Non-Variable Annuities
    Dynamic Assumption-Setting for Variable and Non-Variable Annuities Examination of full surrender ... contract holder is utilizing the GLWB benefit. 17% Both Ruark and LIMRA consider that a contract is ...

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    • Authors: Mark Birdsall, Marianne C Purushotham
    • Date: Sep 2015
    • Competency: Professional Values>Practice expertise; Technical Skills & Analytical Problem Solving>Innovative solutions
    • Publication Name: The Financial Reporter
    • Topics: Annuities>Policyholder behavior - Annuities; Annuities>Variable annuities
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