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Guidance Released on COLI Best Practice Rules
4) is issued or “materially changed” after Aug. 17, 2006. An applicable policyholder is a person who ... rules apply only to contracts “issued” after Aug. 17, 2006, and because the notice and con- sent requirements ...- Authors: Application Administrator, Bryan W Keene, Joel Winston Mann
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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On Grandfathers and Adjustments: New IRS Chief Counsel Advice Memo Blurs Lines
Chief Counsel Advice Memorandum 200805022 (Aug. 17, 2007) (the “CCA”), the Service essentially concludes ... “materially changed” on or after a certain date.17 The Service acknowledged that the TAMRA conference ...- Authors: Application Administrator, Craig R Springfield
- Date: May 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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The Road to the Remediation Revolution: A Short History of the Correction Procedures for Life Insurance and Annuity Contracts
whole.” After the issuance of Revenue Ruling 91-17, the Service saw an increase in waiver ruling requests ... correction programs announced in Revenue Ruling 91-17 and Revenue Procedure 92-25, analogized to ...- Authors: Application Administrator, Walter Welsh, Alison R Peak
- Date: Feb 2009
- Competency: External Forces & Industry Knowledge; Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Annuities; Life Insurance; Public Policy
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Tapping a New Revenue Source – Congress Expands the Medicare Tax Base to Include Income from “Annuities”
Tapping a ... Issue SEPTEMBER 2010 TAXING TIMES | 17 TAPPING A NEW REVENUE SOURCE— CONGRESS ExPANDS ... 18 TAPPING A NEW REVENUE SOURCE … | FROM PAGE 17 18 | TAXING TIMES SEPTEMBER 2010 or business in ...- Authors: Application Administrator
- Date: Sep 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Public Policy
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New IRS Letter Ruling Provides Guidance on Substantially Equal Periodic Payments from Immediate Variable Annuities
presented. The Service responded by affirming the ruling.17 However, logic and reason ultimately prevailed on ... amount. : New IRS Letter Ruling ... from pg. 17 18 4TAXING TIMES payments based on interest rate ...- Authors: Application Administrator, Bryan W Keene, Alison L Reynolds
- Date: Sep 2008
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Annuities>Payout annuities
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T3: TAXING TIMES Tidbits
deductible. In a private letter ruling issued on July 17, 2009, and released to the public on November 6— ... TAM 200448046 (Aug. 30, 2004). 5 TAM 8111079 (Dec. 17, 1980). 6 Rev. Rul. 67-435, 1967-2 C.B. 232. Janel ...- Authors: Application Administrator, Charles J Auer, Craig Pichette, Bryan W Keene, Peter Winslow, Janel C Frank, Gregory K Oyler, Michael Edward Bauer
- Date: Feb 2010
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Financial Reporting & Accounting>Tax accounting
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Life Beyond 100: Rev. Proc. 2010-28 Finalizes the “Age 100 Methodologies” Safe Harbor
calculating net single premiums and necessary premiums.17 Furthermore, to determine the guide- line level premium ... Rev. Proc. 2010-28, § 1. 16 Id., at § 3.02(a). 17 Id., at § 3.02(b). 18 Id., at § 3.02(c). 19 Id ...- Authors: Application Administrator, Brian King, Craig R Springfield
- Date: Feb 2011
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance
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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 ...- 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
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IRS Issues Proposed Safe Harbor Prescribing “Age 100 Methodologies”
receipt doctrine inap- plicable, and Nesbitt v. Comm’r.,17 concluding that the con- structive receipt doctrine ... to an insured’s age 115. 16 39 T.C. 1055 (1963). 17 43 T.C. 629 (1965). 18 It appears that, based ...- Authors: Application Administrator, Brian King, Craig R Springfield, Alison R Peak
- Date: Sep 2009
- Competency: External Forces & Industry Knowledge
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy
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Revenue Ruling 2005-6: Guidanceon QABs under IRS Sections 7702and 7702A
Revenue Ruling 2005-6: Guidanceon QABs under IRS Sections 7702and 7702A On January 19, 2005, the Treasury Department and the Internal ... on QABs under IRC Sections 7702 and 7702A from pg. 17 18 4TAXING TIMES ...- Authors: Application Administrator, Craig R Springfield, Joseph F McKeever
- Date: May 2005
- Competency: Technical Skills & Analytical Problem Solving
- Publication Name: Taxing Times
- Topics: Life Insurance; Public Policy