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  • From the Chair- Forward to 2017!
    From the Chair- Forward to 2017! The Chairperson of the Taxation Section shares the section ... as we met for our first council call of the 2016–17 term, I asked the team (council and friends, especially ...

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    • Authors: Donald Walker
    • Date: Feb 2017
    • Competency: External Forces & Industry Knowledge>External forces and business performance; Leadership>Change management; Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
  • In the Beginning ... How Are Nonqualified Annuities Taxed?
    discussed at length in prior TAXING TIMES articles.17 Exchanges, full and partial. Another beneficial ... case called Webber v. Commissioner, 144 T.C. No. 17 (2015), which describes how not to arrange one’s ...

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    • Authors: John Adney
    • Date: Mar 2016
    • Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Annuities; Public Policy
  • ACLI Update
    ACLI Update Update on industry action on legislative and tax regulatory items affecting the ... particularly adverse impacts on life insurers. On June 17, ACLI submitted a comment letter to Treasury/IRS ...

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    • Authors: Pete Bautz, Mandana Parsazad, Regina Y Rose
    • Date: Oct 2016
    • Competency: Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Public Policy
  • U.S. Tax Aspects of Asset/Liability Matching for Insurance Companies
    related to ordinary liabilities than to capital assets.17 Applying this standard is difficult because, by ... I.R.C. § 1221(b)(2)(A)(i); Treas. Reg. § 1.446-4. 17 T.D. 8555 (preamble), 1994-2 C.B. 180. 18 ...

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    • Authors: Brion Graber, Aditi Banerjee, Peter Winslow
    • Date: Oct 2014
    • Competency: Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Public Policy
  • Proposed Guidance on the New Net Investment Income Tax on “Annuities”
    Frequently Asked Questions on section 1411 (“FAQs”).17 The FAQs address, among other topics, whether additional ... calculating “net gain” from dispositions of property. 17 See http://www.irs.gov/uac/Newsroom/Net-Invest ...

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    • Authors: Alison R Peak, John Adney
    • Date: May 2013
    • Competency: Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Public Policy
  • In the Beginning - Taxation of U.S. Owned Foreign Insurance Operations
    In the Beginning - Taxation of U.S. Owned Foreign Insurance Operations This article is an introduction ... technical difficulties. Ad- JUNE 2016 TAXING TIMES | 17 ministratively, the CFC or U.S. parent company ...

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    • Authors: Timothy Branch
    • Date: Jun 2016
    • Competency: External Forces & Industry Knowledge>Actuarial methods in business operations; Professional Values>Practice expertise; Strategic Insight and Integration>Big picture view
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting; Global Perspectives>Multinational companies; Public Policy
  • Taxing Times, Volume 13, Issue 1, February 2017
    as we met for our first council call of the 2016–17 term, I asked the team (council and friends, especially ... rollovers. With the publication of Rev. Proc. 2016-17, however, the IRS showed its intent was not to cre- ...

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    • Authors: Society of Actuaries
    • Date: Feb 2017
    • Competency: External Forces & Industry Knowledge>External forces and business performance; Leadership>Change management; Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
  • 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
  • Taxing Times, Volume 13, Issue 2, June 2017
    contract,16 (2) increasing benefits under a policy,17 (3) conversion of collectively renewable accident ... 1984, at 604 (1984). (“The 1984 Act Blue Book”). 17 Rev. Rul. 69-444, 1969-2 C.B. 145 18 I.R.S. Priv ...

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    • Authors: Society of Actuaries
    • Date: Jun 2017
    • Competency: External Forces & Industry Knowledge>External forces and business performance; Professional Values>Practice expertise
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting; Public Policy