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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 ...

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    • 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
  • Taxing Times, May 2007, Volume 3, Issue No. 2
    forward to May 2007 and the countdown is on, with only 17 months to go. As most of our readers are well aware ... funds’ as the term is used in the acts of Congress.”17 Treas. Reg. § 1.801-4(e)(5) would also appear to ...

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    • Authors: Application Administrator, Christian J DesRochers, Edward Robbins, Leslie Chapman, Brian King, Kory Olsen, Frederic Gelfond, Craig R Springfield, Bryan W Keene, Peter Winslow
    • Date: May 2007
    • Publication Name: Taxing Times
  • Taxing Times, September 2007, Volume 3, Issue No. 3
    special rules for the treatment of variable contracts.17 Specifically, I.R.C. § 817(c) provides that — ... income amount for non-life insurance companies. 17 The I.R.C. § 817(d) definition of “variable contract” ...

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    • Authors: Christian J DesRochers, Leslie Chapman, Brian King, Kory Olsen, Susan Hotine, Peter Winslow, Thomas Gibbons
    • Date: Sep 2007
    • Publication Name: Taxing Times
  • Options for Inclusion of Stochastic Reserves
    do permit company-specific assumptions to govern,17 as well as other statements in the legislative history ... H.R. Rep. No. 98-432, pt. 2, at 599–600 (1984). 17 E.g., I.R.C. § 807(d)(2)(C) permitting adjustments ...

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    • Authors: Peter Winslow
    • Date: Mar 2016
    • Competency: Technical Skills & Analytical Problem Solving>Problem analysis and definition
    • Publication Name: Taxing Times
  • Taxing Times, May 2005, Volume 1, Issue No. 1
    Taxing Times, May 2005, Volume 1, Issue No. 1 Full version of Taxing Times, May 2005, Volume 1, ... on QABs under IRC Sections 7702 and 7702A from pg. 17 18 4TAXING TIMES The well-known Canadian author ...

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    • Authors: Application Administrator, Christian J DesRochers, Douglas N Hertz, Edward Robbins, Brian King, Craig R Springfield, Tom Quinn, Susan Hotine, Peter Winslow, Joseph F McKeever
    • Date: May 2005
    • Publication Name: Taxing Times