Aug 15, 2016
The Insurance Branch in IRS Chief Counsel’s National Office recently issued a Chief Counsel Advice (CCA) memorandum regarding the Dividends Received Deduction in the separate account partnership fund context. The conclusions reached in the CCA constituted a victory of significance for the taxpayer involved, and while not constituting precedent, should benefit other life insurance companies in comparable situations. From the June 2016 Taxing Times. Written by Samuel A. Mitchell and John T. Adney. Read by Dan Theodore, FSA, MAAA.