ITB 12-14: IRS ruled that insurance sub is eligible to be part of the parent's consolidated group

Insurance Tax Bulletin
The IRS recently published PLR 201210015, dated December 2, 2011, in which it ruled that Sub, a corporation other than a life insurance company (nonlife company) as defined under Treas. Reg. §1.1502-47(d)(7) that will become a life insurance company (life company)as defined under Treas. Reg. §1.1502-47(d)(6), qualifies as an eligible corporation to be included as a life member of the life subgroup as defined under Treas. Reg. §1.1502-47(d)(8) of the parent's consolidated group, as defined under §1504(c) of the Internal Revenue Code of 1986, as amended (IRS, Code).

Return to Tax research and insights
Insurance Tax Bulletin newsletter archive