Lori J. Jones -- Publications

Selected Issues and Developments in Federal Income Taxes

Selected Issues and Developments in Federal Income Taxes, The Insurance Receiver, Volume 24, Number 2. (Co-authored with Michael C. Warren). Click Here for Full Text (PDF).

 

 

IRS Concludes in CCA That Section 197 Applies to All Section 1060 Indemnity Reinsurance Transactions

IRS Concludes in CCA That Section 197 Applies to All Section 1060 Indemnity Reinsurance Transactions, T3: Taxing Times Tidbits, , Taxing Times, Vol . 11, Issue 2 (June 2015) Click Here for Full Text (PDF).

Two PLR’s Provide Some Clarity on Section 351 and Indemnity Reinsurance

Two PLRs Provide Some Clarity on Section 351 and Indemnity Reinsurance, T3: Taxing Times Tidbits, Taxing Times, Vol . 11, Issue 2 (June 2015) Click Here for Full Text (PDF).

IRS Confirms Application of SRLY Cumulative Register Concept to Dual Consolidated Losses

IRS Confirms Application of SRLY Cumulative Register Concept to Dual Consolidated Losses, T3: Taxing Times Tidbits, 43 Taxing Times, Vol. 8, Issue 1 (February 2012). Click here for Full Text (PDF

New Developments for Life/Nonlife Consolidated Returns and the Disproportionate Asset Acquisition Rules

New Developments for Life/Nonlife Consolidated Returns and the Disproportionate Asset Acquisition Rules, 15 Taxing Times, Vol. 7, Issue 2 (May 2011). Click here for Full Text (PDF)

IRS Proposes Separate Entity Treatment for a Cell

IRS Proposes Separate Entity Treatment for a Cell, 17 Taxing Times, Vol. 7, Issue 1 (February 2011) (co-authored with Janel C. Frank). Click here for Full Text (PDF)

The Mystery of PLR 201006002

The Mystery of PLR 201006002, 41 Taxing Times, Vol. 6, Issue 3 (September 2010) (co-authored with Julie V. Goosman). Click here for Full Text (PDF)

Extension of the NOL Carryback Period Also Applies to Life Companies

Extension of the NOL Carryback Period Also Applies to Life Companies, 5 EXPECTFOCUS, Vol. 1, Issue 1 (Winter 2010) (co-authored with Dave Rifkin). Click here for Full Text (PDF)

Change in Basis of Computing Reserves — Is It or Isn’t It?

Change in Basis of Computing Reserves — Is It or Isn’t It?, 9 Taxing Times, Vol. 6, Issue 1 (February 2010) (co-authored with Peter H. Winslow). Click here for Full Text (PDF)

A Practical Guide for Determining Whether a Section 338(h)(10) Election Should Be Made for a Target Insurance Company

A Practical Guide for Determining Whether a Section 338(h)(10) Election Should Be Made for a Target Insurance Company, 25 Taxing Times, Vol. 5, Issue 1 (February 2009). Click here for Full Text (PDF)