Description: The financial crisis of the recent past has prompted the director of the financial services industry portion of the Large and Mid-Size Business “LMSB” Division of the Internal Revenue Service “Service” to announce an increased focus during audit on the reporting by members of the financial services industry of losses attributable to bad debts or to worthless securities issued by subsidiaries.

Description: This article is a general discussion about prior correction procedures for failed life insurance contracts and the new IRS procedure for remediation.

Description: A discussion of the Open Transaction Doctrine and how it was applied to prevent current inclusion of taxable gains resulting from the sale of stock acquired in a demutualization.

Description: Discusses how companies must ensure that significant and necessary product development, and administrative and compliance system changes, have been completed and tested in time to accommodate new requirements.

Description: This article is a general discussion about earnings rates and toll charges and how to compute them.

Description: On July 14, 2005, the FASB issued an Exposure Draft of a proposed Interpretation, Accounting for Uncertain Tax Positions—an Interpretation of FASB Statement No. 109. If adopted, the proposed Interpretation is the most significant tax accounting guidance the FASB has issued since FASB Statement No. 109 “Accounting for Income Taxes,” FAS 109 in 1992.

Description: This editorial highlights the peer review process that all articles in the newsletter go through.

Description: The article discusses the recent final and proposed regulations published by the IRS and Treasury on the required minimum distribution rules for qualified plans, which implement changes made by SECURE 1.0 and SECURE 2.0. The article is intended to identify the important rules in the final regulations, provide a framework for determining how the rules apply to beneficiaries of qualified plans and IRAs, describe the key differences between the earlier 2022 proposed regulations and the final regulations, and it summarizes the SECURE 2.0 provisions contained in the new proposed regulations.

Description: The article discusses recently-issued regulations under section 807 of the Internal Revenue Code, concerning the computation and reporting of reserves. The provisions addressed generally relate to the Tax Cuts and Jobs Act of 2017.

Description: 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 discussed.