ANALYSIS: The Obama Administration has, on several occasions, proposed as a revenue measure an “expansion of the pro rata interest expense disallowance for COLI” (“The proposal”).
CITE: DEPT. OF THE TREASURY, GENERAL EXPLANATIONS OF THE ADMINISTRATION’S FISCAL YEAR 2014 REVENUE PROPOSALS, 77 –78 (2013); Ken Kies, History of Corporate-Owned Life Insurance (COLI) Reforms (Dec. 2013); AALU Policy White Paper, Reject the COLI Pro-Rata Interest Disallowance Proposal (Dec. 2013).
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