View Rule
View EO 12866 Meetings | Printer-Friendly Version Download RIN Data in XML |
TREAS/IRS | RIN: 1545-BH11 | Publication ID: Spring 2009 |
Title: Application of Section 338 to Insurance Companies | |
Abstract: These proposed regulations by reference to temporary regulations incorporated within TD 9257 (71 FR 17990) provide guidance in the following areas: Guidance is provided with regard to the determination of the adjusted basis of section 197 amortizable assets resulting from certain reinsurance transactions and the interplay of those rules with regard to the requirement for the capitalization by insurance companies of policy acquisition expenses. These proposed regulations by reference to the temporary regulations provide rules that apply to insurance reserve increases by a new target insurance company after a stock purchase which is treated as a deemed asset sale under section 338. Additionally, these proposed regulations by reference to temporary regulations also allow the new target insurance company in a deemed asset sale to use the historical loss payment pattern elected by the old target under section 846(e) to continue to be used by new target insurance company, unless new target chooses to revoke that existing election. | |
Agency: Department of the Treasury(TREAS) | Priority: Substantive, Nonsignificant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Completed Actions |
Major: No | Unfunded Mandates: No |
CFR Citation: 26 CFR 1.197-2 26 CFR 1.338-1 26 CFR 1.338-11 26 CFR 1.846-2 26 CFR 1.846-4 ... (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 USC 7805 26 USC 197(f)(5) 26 USC 338 26 USC 846(e) |
Legal Deadline:
None |
||||||||||||
Timetable:
|
Additional Information: REG-118861-00 Drafting attorney: William T. Sullivan (202) 622-7052 Reviewing attorney: Donald J. Drees (202) 622-3970 Treasury attorney: Mark Smith (202) 622-0180 CC: FIP | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Small Entities Affected: No | Federalism: No |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Related RINs: Related to 1545-AY49 | |
Agency Contact: William T. Sullivan Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 3550, Washington, DC 20224 Phone:202 622-7052 Fax:202 622-6275 Email: william.t.sullivan@irscounsel.treas.gov |