ITB 11-74: Reserve amount calculation for foreign report purposes is an acceptable method to measure insurers' foreign personal holding company income

Insurance Tax Bulletin
In PLR 201151008 the IRS said underwriting reserves and loss reserves for life insurance and annuity contracts, required to be maintained by controlled foreign corporations in annual financial statement reporting to a foreign regulatory agency, are an appropriate means of measuring income within the meaning of Section 954(i)(4)(B)(ii)and, accordingly, are the amount of reserves that may be used in determining each company's foreign personal holding company income under Section 954.

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