Samuel A. Mitchell -- Publications

Significant LB&I Examination Developments

Significant LB&I Examination Developments, Taxing Times, Vol. 12, Issue 3 (October 2016). Click Here for Full Text (PDF).

Potential Investment Tax Reform for Insurance Companies

Samuel A. Mitchell, Potential Investment Tax Reform for Insurance Companies, Journal of Taxation of Financial Products, Volume 14, Issue 1, 2016 (Wolters Kluwer (CCH))

A copy of the publication is available at the request of the author or can be obtained from the publishing company, Wolters Kluwer (CCH).

IRS Issues Guidance on the Separate Account Dividends Received Deduction

IRS Issues Guidance on the Separate Account Dividends Received Deduction, Taxing Times, Vol. 12, Issue 2 (June 2016). (Co-authored with John T. Adney). Click Here for Full Text (PDF).

 

 

Insurance Perspectives – Expensing Option Costs Used for Hedging for Clear Reflection of Income

Samuel A. Mitchell, Insurance Perspectives – Expensing Option Costs Used for Hedging for Clear Reflection of Income, Journal of Taxation of Financial Products, Volume 13, Issue 2, 2015 (Wolters Kluwer (CCH))

A copy of the publication is available at the request of the author or can be obtained from the publishing company, Wolters Kluwer (CCH).

LB&I Directive on Insurance Company Hedging of Variable Annuity Guaranteed Benefits

Samuel A. Mitchell, Insurance Perspectives – LB&I Directive on Insurance Company Hedging of Variable Annuity Guaranteed Benefits, Journal of Taxation of Financial Products, Volume 12, Issue 3, 2015 (Wolters Kluwer (CCH))

A copy of the publication is available at the request of the author or can be obtained from the publishing company, Wolters Kluwer (CCH).  

LB&I Revises IDR Directives

LB&I Revises IDR Directives. Taxing Times, Vol. 10, Issue 3 (October 2014) Click Here For Full Text (PDF),

Conclusive Presumption of Worthlessness for Bad Debts

Samuel A. Mitchell, Conclusive Presumption of Worthlessness for Bad Debts, Journal of Taxation of Financial Products, Vol. 12, Issue 1, 2014 at 17 (Wolters Kluwer (CCH)).

 

A copy of the publication is available at the request of the author or can be obtained from the publishing company, Wolters Kluwer (CCH).  

LB&I Releases Good News/Bad News IDR Procedures

LB&I Releases Good  News/Bad News IDR  Procedures. Taxing Times, Vol. 10, Issue 1 (February 2014) (Samuel A. Mitchell) Click Here for Full Text (PDF),

Agent Advances – Loans or Compensation?

Agent Advances – Loans or Compensation?, 7 Expect Focus, Vol. 4 (Fall 2013).  Click Here for Full Text (PDF).

IRS Utilizes the Industry Issue Resolution Program to Resolve the Insurance Industry Bad Debt Issue

IRS Utilizes the Industry Issue Resolution Program to Resolve the Insurance Industry Bad Debt Issue, 20 Taxing Times, Vol. 9, Issue 1 (February 2013). (Co-authored with Arthur C. Schneider, Senior Vice President and Chief Tax Officer, Transamerica Corp.) Click Here for Full Text (PDF).