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Tax Attorney and Tax Actuary Dialogue on IRS Notice 2008-18—AG VACARVM and Life PBR Part III
the section 807 requirements? Peter: There is a direct interconnection between section 816 and section ... has even less support under the 1984 Act. The primary reason given in the ruling for the conclusion is ...- Authors: Christian J DesRochers, Edward Robbins, Peter Winslow
- Date: Mar 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities>Reserves - Annuities; Financial Reporting & Accounting>Tax accounting; Life Insurance>Reserves - Life Insurance
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Actuary/Tax Attorney Dialogue on Selected Tax Issue in Principle-Based Reserves (Part IV)
label as “outside influences” that could have a direct or indirect impact on PBR itself and/or the tax ... issued contracts. In this regard, I think the primary lesson of American Financial is that there is ...- Authors: Peter Winslow
- Date: Feb 2013
- Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Actuarial Profession>Standards of practice; Financial Reporting & Accounting>Tax 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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Accountant/Tax Attorney Dialogue on the History and Purpose of Internal Revenue Code Section 811(a)
premium, guaranteed renewable, group long- term care policies. The IRS held that the use of the company’s ... extremely rare that tax considerations are the primary, or even a leading, driver in determining statutory ...- 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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When Are Guaranty AssociationAssessments Deductible?
focused on: • Life Insurance • Annuities & Long-Term Care Days 2 and 3: General sessions covering current ... include: • Life Insurance • Annuities • Long-term Care • Combination Products The IRS will be invited ...- Authors: Peter Winslow, Lori J Jones
- Date: Sep 2006
- Competency: External Forces & Industry Knowledge>External forces and business performance
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Statutory accounting; Financial Reporting & Accounting>Tax accounting
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T3: Taxing Times Tidbits
following the date when states with 75 percent of direct premiums written have adopted the change.2 This ... defers to states having at least 75 percent of direct written premiums for the implemen- tation of its ...- Authors: Kory Olsen, Peter Winslow
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Annuities>Variable annuities; Financial Reporting & Accounting>Tax accounting; Life Insurance
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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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T3: TAXING TIMES Tidbits
T3: TAXING TIMES Tidbits Discussions on: 1. tax deductability of surrender losses of life insurance ... company is used to assume risks from a single direct writer. Revenue Ruling 2009-26 considers two fact ...- Authors: Application Administrator, Charles J Auer, Craig Pichette, Bryan W Keene, Peter Winslow, Janel C Frank, Gregory K Oyler, Michael Edward Bauer
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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VM-20 Deterministic Reserves in Federally Prescribed Reserves
VM-20 Deterministic Reserves in Federally Prescribed Reserves Consideration of the deterministic ... for unaccrued claims.13 In the case of long-term care in- surance, this type of premium deficiency reserve ...- Authors: Peter Winslow
- Date: Jun 2016
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting