ITB 11-53: Reasonable expense charges may be deducted in computing deemed cash surrender value

Insurance Tax Bulletin
In PLR 201137008, the IRS said that for purposes of the necessary premium test under Section 7702A(c)(3)(B)(i), a life insurance company's reasonable expense charges are taken into account when determining the deemed cash surrender value of a policy intended to satisfy the cash value accumulation test under Section 7702(b).

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