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February 2020 issue of Taxing Times
accepted accounting principles (“GAAP”) financials, IFRS financials or the local insurance annual statement ... the entity itself in the active conduct analysis.17 A three-part test must be satisfied for this purpose: ...- Authors: Society of Actuaries
- Date: Feb 2020
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting
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Taxing Times, Volume 14, Issue 3, October 2018
sense operating similar to GAAP, statutory and IFRS financial accounting standards. That is, the determination ... In United Fire Insurance Company v. Commissioner,17 the Seventh Circuit, in rejecting the Service argument ...- Authors: Society of Actuaries
- Date: Oct 2018
- Publication Name: Taxing Times
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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 ...- 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
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IRS Applies Strict Reading of Section 72(s)
the life expectancy rule and the five-year rule.17 Due to circumstances beyond the daughters’ control ... 4170, 98th Cong. § 222 (as passed by Senate, May 17, 1984); S. COMM. ON FINANCE, EXPLANATION OF PROVISIONS ...- Authors: Mark E Griffin, Alison R Peak
- Date: Mar 2016
- Competency: Professional Values
- Publication Name: Taxing Times
- Topics: Annuities>Individual annuities
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Taxing Times, Volume 14, Issue 2, June 2018
statutory reserves, with no cash surrender value floor.17 The life insurance company prora- tion provision ... 2017, H.R. 1628, 115th Cong., 1st Sess. (2017). 17 Chairman’s Mark, section 3703. 18 Chairman’s Mark ...- Authors: Society of Actuaries
- Date: Jun 2018
- Competency: Professional Values>Practice expertise
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Taxing Times
payment of a substantial number of future premiums.17 This definition presents interpretative questions ... applies to life insurance contracts issued after Aug. 17, 2006, except for a contract issued after that date ...- Authors: Society of Actuaries
- Date: Jun 2019
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting
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Accountant/Tax Attorney Dialogue: Part III
insurance contracts as life insurance contracts.17 Might there be circum- stances where the issuer of ... and distribution is MARCH 2016 TAXING TIMES | 17 identifying the person (or entity) that has the ...- Authors: Peter Winslow, Susan Hotine, John Adney, Mark Smith, Sheryl Flum
- Date: Mar 2016
- Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
- Publication Name: Taxing Times
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Investor Control: Will You Know It When You See It?
control rules, Inv. An- nuity, Inc. v. Blumenthal,17 was dismissed by the appellate court due to lack ... Revenue Code of 1986, as amended. 4 144 T.C. No. 17 (June 30, 2015). 5 2003-2 C.B. 347. 6 309 U.S ...- Authors: Ann Cammack, Frederic Gelfond
- Date: Mar 2016
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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tax-2016-vol12-iss1-baxley-flum
insurance policies with which most people are familiar.”17 Whether a loss has occurred cannot be known until ... Slip Op. 35. 15 Slip Op. 36–37. 16 Slip Op. 38. 17 Slip Op. 38. 18 Slip Op. 39. 19 Slip Op. 45. 20 ...- Date: Mar 2016
- Publication Name: Taxing Times
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Taxing Time - Vol 15 Issue 1
use its own contract to fund its in- house plan.17) By and large, ERISA’s rules are most strict when ... employees. 15 ERISA § 406(a). 16 ERISA § 406(b). 17 ERISA § 408(b)(5). 18 ERISA § 103(a)(2). 19 29 ...- Authors: Society of Actuaries
- Date: Mar 2019
- Publication Name: Taxing Times