Mark H. Kovey
(Partner)
- Deferred Compensation Transition Relief Extended Through End of 2007, T3: Taxing Times Tidbits, 34 Taxing Times, Vol. 3, Issue 1 (February 2007). Click here for Full Text (PDF)
- Highlights of the Recent Guidance on Insurance Company Acquisitions, 9 Taxing Times, Vol. 2, Issue 2 (September 2006) (Co-authored with Lori J. Jones).
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- The Final Section 338 and 1060 Regs: Blending Corporate and Insurance Tax Principles, 30 Insurance Tax Review 979 (June, 2006) (Co-authored with Lori J. Jones). Click here for Full Text (PDF)
- Time to Simplify the Life-Nonlife Rules?, 24 Insurance Tax Review 377 (March, 2003). (Co-authored with Lori J. Jones).
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- IRS Issues Comprehensive Guidance on the Application of Sections 338 and 1060 to Insurance Companies, 22 Insurance Tax Review 835 (May, 2002). (Co-authored with Lori J. Jones)
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- Reinsurance Treated as Section 1060 Asset Acquisition; Basis of Insurance in Force Immediately Deductible, 15 Journal of Taxation of Financial Institutions 25 (2002).
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- Watershed IRS Rulings Permit Coinsurance in "Save the Charter" Transactions, 16 Insurance Tax Review 247 (1999). (Co-authored with Lori J. Jones)
- Tax-Free Incorporation Rules Apply to the Formation of an Insurance Company Subsidiary, 82 Journal of Taxation 172 (1995). (Co-authored with Biruta P. Kelly)
- Nonrecognition Treatment Prevails in Assumption Reinsurance Incorporation Ruling, 8 Insurance Tax Review 10 (1994). (Co-authored with Biruta P. Kelly)
- Tax Free Strip Out of Insurance Business to Preserve Insurance Company's Charter, 5 Insurance Tax Review 151 (1991).
- DRA introduces new concepts in altering taxation of life insurance companies, Part II, 63 Journal of Taxation 48 (1985). (Co-authored with Peter H. Winslow and Stephen D. Hooe)
- New law revamps life insurance company computation of reserves and income, Part I, 62 Journal of Taxation 292 (1985). (Co-authored with Peter H. Winslow and Stephen D. Hooe)
- Supreme Court's citation of letter rulings: What does it mean to practitioners?, 55 Journal of Taxation 166 (1981). (Co-authored with Peter H. Winslow)
- Supreme Court in Rowan holds "wages" excludable from income are exempt from FICA, FUTA, 55 Journal of Taxation 130 (1981). (Co-authored with Peter H. Winslow)
- Impact of Supreme Court decision limiting withholding on employees' meal allowances, 48 Journal of Taxation 276 (1978).
- Characterizing Reorganizations by Reference to the Historic Shareholder, 5 Journal of Corporate Taxation 115 (1978).
- Changing shareholders in contemplation of a liquidation: The planning involved, 47 Journal of Taxation 82 (1977).
- Rigged Answers to Troublesome Liquidation Plan Questions, 54 Taxes 258 (1976).
- Courts disagree on treatment of fire loss related expenses under 337, 39 Journal of Taxation 335 (1973).
- When will Section 337 shield fire loss proceeds? A current look at a burning issue, 39 Journal of Taxation 258 (1973).