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Deferred Compensation Could Not Be Deducted Under 2002 Procedure for Insurance Companies, IRS Says  Insurance Update


Author:  John Ensminger.


Source: Volume 20, Number 01, September/October 2006 , pp.23-28(6)




Journal of Taxation and Regulation of Financial Institutions

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Abstract: 

In TAM 200610016, a nonlife insurance company was the parent of an affiliated group filing a consolidated federal income tax return. This insurance company and certain affiliated insurance companies (collectively, “Taxpayer”) sold real property and casualty insurance through independent contractor agents throughout the United States. The questions posed in the TAM were whether Taxpayer could use the safe harbor method for premium acquisition expenses in Rev. Proc. 2002-46 and, if not, if the Taxpayer could apply the correct method only on a prospective basis.

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