CCH (cch.taxgroup.com) reports:
For purposes of determining a life insurance company's taxable income, where the company did business in several states with different minimum reserve requirements, the amount of the company's statutory reserves, within the meaning of Code Sec. 807(d)(6), was the highest aggregate reserve amount set forth on an annual statement pursuant to the minimum reserve requirements of any state in which the company did business. This was the case where the company held and reported to each state the highest aggregate minimum amount of reserves required for its insurance contracts under the laws of all states in which the company transacted business. The same result occurred in a second situation where the company reported to each state the minimum amount of reserves required for its insurance contracts under the laws of that particular state. In that situation, however, the company actually held the highest aggregate minimum amount of reserves required for its insurance contracts under the laws of any state in which the company did business.
Rev. Rul. 2008-37, 2008FED ¶46,492
Other References:
Code Sec. 807
CCH Reference - 2008FED ¶25,821.25
Tax Research Consultant
CCH Reference - TRC NOL: 6,154
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