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T3: TAXING TIMES TIDBITS
In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign ... parties changing the counterparty obligated to a domestic corporation (“Taxpayer”) under an existing agreement ...- Authors: Frederic Gelfond
- Date: Aug 2021
- Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Reinsurance; Reinsurance>General reinsurance
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The Impact of BEAT on U.S.-Foreign Affiliated Reinsurance
The Impact of BEAT on U.S.-Foreign Affiliated Reinsurance Enacted pursuant to the 2017 Tax Cuts and ... and Jobs Act (TCJA) , the base erosion and anti-abuse tax (BEAT) is one of the most dramatic changes to ...- Date: Dec 2020
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Reinsurance
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The Mystery of PLR 201006002
The Mystery of PLR 201006002 An explanation of the reasons why the IRS should rule on the application ... application of section 351 to the transfer of assets and reserves in an indemnity coinsurance transaction where ...- Authors: Julie V Goosman, Lori J Jones
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance
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Assessing the Transfer of Risk: An Actuarial Perspective
Assessing the Transfer of Risk: An Actuarial Perspective This article discusses risk transfer and how ... actuaries, the challenge is to develop an analytical framework under which the presence of insurance risk ...- Authors: Christian J DesRochers
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Finance & Investments>Risk measurement - Finance & Investments; Finance & Investments>Value at risk - Finance & Investments; Reinsurance
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T3: Taxing Times Tidbits
IRS treatment of reinsurance under section 845, and IRS waivers for failed contracts under section 7702 ... insurance;Internal Revenue Service=IRS;Long-term care insurance=LTCI;Taxes=Taxation; 11588 9/1/2009 ...- Authors: Mark E Griffin, Craig R Springfield, Daniela Stoia, Biruta P Kelly
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy; Reinsurance
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Unique Tax issues in LTC transactions
Unique ... long-term care transactions. Includes consideration around the form of reinsurance and the unified loss ... step-down) Premium deficiency reserves, Long-term care reserves 3/18/2019 12:00:00 AM ...- Authors: Peter J Sproul
- Date: Mar 2019
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Long-term Care; Reinsurance
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Insurance Transfer Pricing: Issues For Life Reinsurance Transactions
Insurance Transfer Pricing: Issues For Life Reinsurance Transactions This article describes ... Reinsurance Transactions This article describes the transfer pricing rules applicable to life reinsurance ...- Authors: Christian J DesRochers
- Date: May 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy; Reinsurance