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Abstract: 

In PLR 200544018,13 an insurance company that invested premiums of contract holders in portfolios established by a mutual fund, wished to have the portfolios elect to treat themselves as partnerships so that units in the partnerships could be sold to segregated asset accounts of other domestic life insurance companies. Thus, the portfolios, which were each regulated investment companies, would be treated as pass-through entities with the tax consequences flowing through to the insurance companies (related and unrelated to the original insurance company) responsible for the federal tax liabilities of units in the portfolios they owned.

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