TITLE

Tax Bill Proposal Severely Impacts RMs; IRS Reverses CIF Excise Tax Stance; Association Providing WC Is a Mutual

AUTHOR(S)
Pine, Sidney R.; Wright, P. Bruce
PUB. DATE
May 1984
SOURCE
Risk Management (00355593);May84, Vol. 31 Issue 5, p12
SOURCE TYPE
Trade Publication
DOC. TYPE
Article
ABSTRACT
This section presents an update on legal and taxation issues in the U.S. as of May 1984. The House Ways and Means Committee recently reported out a new tax bill. Two points are of immediate interest to risk managers: the proposal affects the accrual of deductions for workers' compensation benefits and it limits the ability of U.S. corporations to utilize foreign insurer/reinsurers to help secure the benefit of foreign tax credits. The Internal Revenue Service (IRS) has recently reconsidered its position as to whether a reserve for unearned premiums, when set aside by a title insurance company, constitute unearned premiums for the purposes of federal income tax. In Technical Advice Memorandum 8103003, the IRS considered whether a U.S. taxpayer is liable for the excise tax on certain insurance purchased in connection with a cost, insurance and freight contract. The term foreign insurer is defined, in general, to include one who is a nonresident, alien individual or foreign corporation. The IRS recently held that an unincorporated association, created pursuant to a state's workers' compensation law to provide reinsurance coverage to its member at cost, was taxable as a mutual insurance company under Internal Revenue Code §821.
ACCESSION #
15110547

 

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