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...

Jul 15, 2016

The treatment of foreign operations U.S. tax purposes is complex, and the addition of the insurance component adds to the complexity.  This article will give the listener an introduction to the treatment of wholly owned foreign insurance company subsidiaries of US insurers.  From the June 2016 Taxing Times. Written by...

Jun 8, 2016

Since the 1970’s, taxpayers purchasing and selling variable life insurance and annuity contracts have been wary of the “Investor Control Doctrine.”  Authors Ann Cammack and Frederic J. Gelfond provide a lively presentation of the history and issues.  From the March 2016 Taxing Times.  Read by...

May 12, 2016

In September 2015, the Tax Court issued its opinion blessing residual value insurance contracts as “insurance” for federal income tax purposes. Authors Jean Baxley and Sheryl Flum provide a brief backdrop to the “what is insurance” issue, summarize the Tax Court’s opinion in RVI, and offer observations...

Apr 21, 2016

Dan Theodore reads "In The Beginning…A Column Devoted to Tax Basics – How Are Nonqualified Annuities Taxed?" from the March 2016 issue of Taxing Times written By John T. Adney.