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IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine
IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine In March 2010, Congress codified the judicial economic substance doctrine in an effort to raise ...- Authors: Samuel A Mitchell
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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The Open Transaction Doctrine Applies to the Sale of Stock of a Demutualized Life Insurer in Fisher, But Should It?
The Open Transaction Doctrine Applies to the Sale of Stock of a Demutualized Life Insurer in Fisher, But Should It? A discussion of the Open Transaction Doctrine and how it was applied to prevent ...- Authors: Emanuel Burnstein
- Date: May 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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T3: Taxing Times Tidbits - What to do About Tax Reserve Estimates
T3: Taxing Times Tidbits - What to do About Tax Reserve Estimates We frequently are asked what to do when a company has reported aggregate estimates of tax reserves on the tax return, instead of ...- Authors: Susan Hotine, Peter Winslow, Samuel A Mitchell
- Date: Dec 2005
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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T3: Taxing Times Tidbits
T3: Taxing Times Tidbits A discussion about foreign currency hedging, foreign insurance excise tax, taxation of credit default swaps and bad debts. Asset valuation;Audits;Credit default swaps; ...- 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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Common Myths in Interpreting the Company Tax Provisions of the 1984 Act
Common Myths in Interpreting the Company Tax Provisions of the 1984 Act The author discusses some common myths about Congress’ tax policy under the 1984 Act that he would like “to debunk.” ...- Authors: Peter Winslow
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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Change in Basis of Computing Reserves—Is It Or Isn’t It?
Change in Basis of Computing Reserves—Is It Or Isn’t It? High on the list of the most frequently asked questions by tax professionals working for life insurance companies is whether a change in ...- Authors: Peter Winslow, Lori J Jones
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting; Public Policy
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From The Chair - Guess What
From The Chair - Guess What Discussion about the recent activities of the Taxation Section and its council and plans for the future. The project of the NPT [Necessary Premium Test] task force was ...- Authors: Kristin Schaefer
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Actuarial Profession; Public Policy
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PLR 201120011 Highlights the Need for SEPP Guidance on Annuities
PLR 201120011 Highlights the Need for SEPP Guidance on Annuities Owners of nonqualified annuity contracts, individuals under qualified retirement plans, and annuity issuers are left without ...- Authors: Mark E Griffin
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities; Public Policy
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IRS Issues Guidance and Seeks Comments on LTC Insurance Product Issues
IRS Issues Guidance and Seeks Comments on LTC Insurance Product Issues On Aug. 11, 2011, the Internal Revenue Service IRS released Notice 2011-68,1 regarding the tax treatment of stand-alone and ...- Authors: Craig R Springfield, Bryan W Keene
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Long-term Care>Long-term care insurance; Public Policy
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The Interaction of Section 7702 and the Nonforfeiture Law - Trouble Ahead for Traditional Life Insurance
The Interaction of Section 7702 and the Nonforfeiture Law - Trouble Ahead for Traditional Life Insurance The interaction of section 7702 cash value accumulation test [CVAT] and state ...- Authors: Christian J DesRochers, Benjamin J. Yahr
- Date: Feb 2012
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy