Instructions For Form 1120-Pc - 2008 Page 17

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2. Applicable interest rate, and
before the beginning of the accident year.
capital asset on this schedule and the rest
3. Applicable loss payment pattern.
The election will not apply to any
on Schedule D (Form 1120). Otherwise,
international or reinsurance line of
do not include on Schedule D (Form
Special rules apply with respect to:
business. If the corporation makes this
1120) any sales reported on this
Unpaid losses related to disability
election, check the “Yes” column for
schedule.
insurance (other than credit disability
question 7 in Schedule I, Other
insurance),
Information. For more information, see
Noncancelable accident and health
Schedule H—Special
section 846(e), Regulations section
insurance,
1.846-2, and Rev. Proc. 92-76, 1992-2
Deduction and Ending
Cancelable accident and health
C.B. 453.
insurance, and
Adjusted Surplus for
Note. There is a special application of
International and reinsurance lines of
the “fresh start” provision for an insurance
Section 833 Organizations
business.
company that is not subject to tax under
With regard to the special rules for
section 831(a) for its first tax year
Line 5. Beginning adjusted surplus. If
discounting unpaid losses on accident
beginning after December 31, 1986,
the corporation was a section 833
and health insurance (other than disability
because (1) it is described in section
organization in 2007, it should enter the
income insurance), unpaid losses are
501(c) or (2) it is subject to tax under
amount from Schedule H, line 10, of its
assumed to be paid in the middle of the
section 831(b) on its investment income.
2007 Form 1120-PC.
year following the accident year.
If the insurance company later
Generally, the adjusted surplus as of
Generally, the amount of undiscounted
becomes subject to tax under section
the beginning of any tax year is an
unpaid losses means the unpaid losses
831(a), the rules relating to the fresh start
amount equal to the adjusted surplus as
and unpaid loss adjustment expenses
under the discounting provisions are
of the beginning of the preceding tax
shown in the annual statement. However,
applied by treating the last tax year before
year:
see Regulations section 1.846-1(a)(1)
the year in which the insurance company
1. Increased by the amount of any
referring to Regulations section
becomes subject to tax under section
adjusted taxable income for the preceding
1.832-4(b) relating to the determination of
831(a) as the insurance company’s last
tax year or
unpaid losses.
tax year beginning before 1987. See
2. Decreased by the amount of any
section 1010(e) of the Technical and
Under section 832(b)(5)(A), unpaid
adjusted net operating loss for the
Miscellaneous Revenue Act of 1988 and
losses must be adjusted to take into
preceding tax year.
Notice 88-100, 1988-2 C.B. 439.
account estimated recoveries due to
salvage and reinsurance for those losses.
Lines 6 and 7. Estimated salvage and
If 2008 is the first tax year the taxpayer
If the amounts shown in the annual
reinsurance recoverable. Enter on
qualifies as a section 833 organization,
statement were determined on a
lines 6 and 7 the amount of estimated
see section 833(c)(3)(C) to determine the
discounted basis and if the extent to
salvage and reinsurance recoverable.
adjusted surplus as of the beginning of
which these losses were discounted can
The amount of estimated salvage
the 2008 tax year.
be determined on the basis of information
recoverable must be determined on a
For purposes of the computation of the
disclosed on or with the annual
discounted basis. The salvage discount
adjusted surplus, the terms “adjusted
statement, the amount of the
factors for 2008 are published in Rev.
taxable income” and “adjusted net
undiscounted unpaid losses must be
Proc. 2008-71, 2008-49 I.R.B. 1251. The
operating loss” mean the taxable income
recomputed to eliminate any reduction
salvage discount factors for 2009 will be
or the net operating loss, respectively,
caused by such discounting. In no event
published in the Internal Revenue Bulletin
determined with the following
can the amount of discounted unpaid
when available. Also see Regulations
modifications:
losses with respect to any line of business
section 1.832-4.
1. Without regard to the deduction
for an accident year exceed the total
Line 9. Tax-exempt interest subject to
determined under section 833(b)(1);
amount of unpaid losses with respect to
section 832(b)(5)(B). Enter the amount
2. Without regard to any carryover or
any line of business for an accident year
of tax-exempt interest received or
carryback to that tax year; and
as reported on the annual statement. Also
accrued during the tax year on
3. By increasing gross income by an
see Regulations section 1.832-4(d)
investments made after August 7, 1986.
amount equal to the net exempt income
regarding increasing unpaid losses shown
For information regarding the
for the tax year.
on the annual statement by salvage
determination of the acquisition date of an
recoverable. Also see Rev. Proc. 92-77,
investment, see the instructions for
Line 6. Special deduction. The
1992-2 C.B. 454.
Schedule C.
deduction for any tax year is limited to
The applicable interest rate for each
taxable income for that tax year
calendar year and the applicable loss
determined without regard to this
Schedule G—Other
payment pattern for each accident year
deduction.
for each line of business are determined
Capital Losses
Note. Under section 833(b)(4), any
by the IRS. The applicable interest rate
determination under section 833(b) must
and loss payment patterns for 2008 are
Capital assets are considered sold or
be made by only taking into account items
published in Rev. Proc. 2008-70, 2008-49
exchanged to provide funds to meet
from the health-related business of the
I.R.B. 1240. The applicable interest rate
abnormal insurance losses and to pay
corporation.
and loss payment patterns for 2006 and
dividends and make similar distributions
2007 are published in Rev. Proc. 2007-9,
Line 8a. Adjusted tax-exempt income.
to policyholders to the extent that the
2007-3 I.R.B. 278, and 2008-10, 2008-3
Reduce the total tax-exempt interest
gross receipts from their sale or exchange
I.R.B. 290, respectively.
received or accrued during the tax year
are not more than the amount by which
by any amount (not otherwise deductible)
the sum of dividends and similar
Corporations having sufficient
which would have been allowable as a
distributions paid to policyholders, losses
historical experience to determine a loss
deduction for the tax year if such interest
paid, and expenses paid for the tax year
payment pattern may, under certain
were not tax-exempt. Enter the result on
is more than the total on line 9, Schedule
circumstances, elect under section 846(e)
line 8a.
G.
to use their own historical experience
(instead of the loss payment patterns
Total gross receipts from sales of
Line 8b. Adjusted dividends-received
determined by the IRS). If this election is
capital assets (line 12, column (c)) must
deduction. Reduce the total amount
made, the loss payment patterns will be
not be more than line 10. If necessary,
allowed as a deduction under sections
based on the most recent calendar year
the corporation may report part of the
243, 244, and 245 by the amount of any
for which an annual statement was filed
gross receipts from a particular sale of a
decrease in deductions allowable for the
-17-
Instructions for Form 1120-PC

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