ITB 12-16: IRS seeks comments on collection requirements related to the the application of section 338 to insurance businesses
Insurance Tax Bulletin
On April 6, 2012, the IRS announced in the Federal Register that it is soliciting comments concerning collection requirements related to the application of § 338 to insurance companies as addressed in final Regs (T.D. 9377). The relevant regulations address determining the adjusted basis of amortizable § 197 intangibles for insurance contracts, increases in reserves after a deemed asset sale, and the effect of a § 338 election to use a company's historical loss payment pattern.