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  • Treasury Issues Proposed Rules for Determining Active Income of Certain Foreign Insurance Companies
    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: ...

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    • Authors: Jay Riback, Jean Baxley
    • Date: Feb 2020
    • Competency: Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Finance & Investments; Finance & Investments>Investments; Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting
  • ACLI Update
    to the OECD Pillar Two model rules with Examples.[17] ACLI engaged with GFIA to develop a comment letter ... e-erosion-model-rules-pillar-two-commentary.pdf [17] Examples may be found here: https://www.oecd.or ...

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    • Authors: Mandana Parazad, Regina Y Rose, Sarah Lashley
    • Date: Sep 2022
    • Competency: External Forces & Industry Knowledge; Strategic Insight and Integration
    • Publication Name: Taxing Times
    • Topics: Health & Disability; Life Insurance
  • IRS’s Proposed LRD Rules for Nonlife Reserves are Out
    of not more than seventeen and one- half years.”17 The choice of maturity range was unanticipated by ... taxpayer comments on this issue in Rev. Proc. 2003- 17, and commenters expressed a desire for the IRS to ...

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    • Authors: Jay Riback
    • Date: Mar 2019
    • Competency: Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Financial Reporting & Accounting>Tax accounting; General Insurance (Property & Casualty)>Reserves - General Insurance
  • Proposed Regulations on Ownership Change Present Issues for Insurance Companies
    Proposed Regulations on Ownership Change Present Issues for Insurance Companies This article ... the proposed regulations. (See letter, page 19.) 17 The proposed regulations take the position that the ...

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    • Authors: Samuel A Mitchell, Arthur C Schneider
    • Date: Jun 2020
    • Competency: Strategic Insight and Integration
    • Publication Name: Taxing Times
    • Topics: Finance & Investments; Financial Reporting & Accounting; Financial Reporting & Accounting>Tax accounting
  • LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years
    LB&I Directive Provides Safe Harbor for AG43 and PBR for Pre-TCJA Years This article ... (GMxB) by Insurance Companies, LB&I-04-0514-0050 (July 17, 2014). See also Eric Bisighini & Tim Branch, Variable ...

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    • Authors: Samuel A Mitchell, Arthur C Schneider
    • Date: Mar 2019
    • Competency: External Forces & Industry Knowledge; Strategic Insight and Integration; Technical Skills & Analytical Problem Solving
    • Publication Name: Taxing Times
    • Topics: Annuities>Guaranteed living benefits; Life Insurance>Reserves - Life Insurance; Life Insurance>Secondary guarantees