IRS provides insurers with safe harbor for some bad debt deductions

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The Large Business and International (LB&I) Division of the Internal Revenue Service released an Industry Director Directive (IDD) allowing insurance companies to elect what is effectively a safe harbor for partial worthlessness deductions with respect to loan backed and structured securities as defined in Statement of Statutory Accounting Principle (SSAP) 43R. The new safe harbor is patterned after the safe harbor under Treas. Reg. Section 166-2(d). Taxpayers are permitted to make this one-time election going back to the 2009 taxable year, through the 2012 taxable year, with a true-up adjustment and full audit protection for years prior to, and including, the year of election.


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