Description: This article discusses the complexities of such a simple statement as well as highlight certain differences between tax and book treatment of that capitalization.

Description: A discussion of: IRS requirement disclosures of uncertain tax positions, disallowed interest reductions on earnings and profits, and tax standards for partial worthlessness deductions.

Description: Internal Revenue Code (I.R.C.) §§243–2461 provide that a corporation is allowed a percentage deduction for dividends received from other corporations (the DRD). In addition to the general corporate rules regarding the DRD, if the recipient of a corporate dividend is a life insurance company, I.R.C. §812(a) further allocates the benefit of the DRD between the company’s share and the policyholders’ share. This allocation methodology is often referred to as proration. Proration has historically involved a complex and at times contentious2 formulaic process.

Description: Status update on the Separate Account Dividends Received Deduction, SADRD.