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Interinsurer Providing Professional Liability Insurance for Professional Association Structured to Obtain Tax Benefits  


Author:  Staff Editors.


Source: Volume 20, Number 05, May/June 2007 , pp.57-59(3)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

In PLR 200701026, “Company” is a “State A” domiciled captive reciprocal risk retention group that qualifies as an interinsurer for federal income tax purposes. It provides claims-made professional liability and occurrence general liability coverage. Company’s representatives requested was that Company be permitted a deduction under Section 832(f) as an interinsurer. The request was granted

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