Instructions For Form 1120-Pc - 2005 Page 18

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1. Amount of the undiscounted unpaid
circumstances, elect under section 846(e)
are not more than the amount by which
losses,
to use their own historical experience
the sum of dividends and similar
2. Applicable interest rate, and
(instead of the loss payment patterns
distributions paid to policyholders, losses
3. Applicable loss payment pattern.
determined by the IRS). If this election is
paid, and expenses paid for the tax year
made, the loss payment patterns will be
is more than the total on line 9, Schedule
Special rules apply with respect to:
based on the most recent calendar year
G.
Unpaid losses related to disability
for which an annual statement was filed
Total gross receipts from sales of
insurance (other than credit disability
before the beginning of the accident year.
capital assets (line 12, column (c)) must
insurance),
The election will not apply to any
not be more than line 10. If necessary,
Noncancelable accident and health
international or reinsurance line of
the corporation may report part of the
insurance,
business. If the corporation makes this
gross receipts from a particular sale of a
Cancelable accident and health
election, check the “Yes” column for
capital asset on this schedule and the rest
insurance, and
question 7 in Schedule I, Other
on Schedule D (Form 1120). Otherwise,
International and reinsurance lines of
Information. For more information, see
do not include on Schedule D (Form
business.
section 846(e), Regulations section
1120) any sales reported on this
1.846-2, and Rev. Proc. 92-76, 1992-2
With regard to the special rules for
schedule.
C.B. 453.
discounting unpaid losses on accident
and health insurance (other than disability
Note. There is a special application of
income insurance), unpaid losses are
the “fresh start” provision for an insurance
Schedule H—Special
assumed to be paid in the middle of the
company that is not subject to tax under
Deduction and Ending
year following the accident year.
section 831(a) for its first tax year
beginning after December 31, 1986,
Generally, the amount of undiscounted
Adjusted Surplus for
because (1) it is described in section
unpaid losses means the unpaid losses
Section 833 Organizations
501(c) or (2) — it is subject to tax under
and unpaid loss adjustment expenses
section 831(b) on its investment income.
shown in the annual statement. However,
Line 5. Beginning adjusted surplus. If
see Regulations section 1.846-1(a)(1)
If the insurance company later
the corporation was a section 833
referring to Regulations section
becomes subject to tax under section
organization in 2004, it should enter the
1.832-4(b) relating to the determination of
831(a), the rules relating to the fresh start
amount from Schedule H, line 10, of its
unpaid losses.
under the discounting provisions are
2004 Form 1120-PC.
applied by treating the last tax year before
Under section 832(b)(5)(A), unpaid
Generally, the adjusted surplus as of
the year in which the insurance company
losses must be adjusted to take into
the beginning of any tax year is an
becomes subject to tax under section
account estimated recoveries due to
amount equal to the adjusted surplus as
831(a) as the insurance company’s last
salvage and reinsurance for those losses.
of the beginning of the preceding tax
tax year beginning before 1987. See
If the amounts shown in the annual
year:
section 1010(e) of the Technical and
statement were determined on a
1. Increased by the amount of any
Miscellaneous Revenue Act of 1988 and
discounted basis and if the extent to
adjusted taxable income for the preceding
Notice 88-100, 1988-2 C.B. 439.
which these losses were discounted can
tax year or
be determined on the basis of information
Lines 6 and 7. Estimated salvage and
2. Decreased by the amount of any
disclosed on or with the annual
reinsurance recoverable. Enter on lines
adjusted net operating loss for the
statement, the amount of the
6 and 7 the amount of estimated salvage
preceding tax year.
undiscounted unpaid losses must be
and reinsurance recoverable. The amount
recomputed to eliminate any reduction
of estimated salvage recoverable must be
If 2005 is the first tax year the taxpayer
caused by such discounting. In no event
determined on a discounted basis. The
qualifies as a section 833 organization,
can the amount of discounted unpaid
estimated salvage discount factors for
see section 833(c)(3)(C) to determine the
losses with respect to any line of business
2005 are published in Rev. Proc.
adjusted surplus as of the beginning of
for an accident year exceed the total
2005-73, 2005-49 I.R.B. 1090. The 2006
the 2005 tax year.
amount of unpaid losses with respect to
estimated salvage and reinsurance rates
any line of business for an accident year
For purposes of the computation of the
will be published in the Internal Revenue
as reported on the annual statement. Also
adjusted surplus, the terms “adjusted
Bulletin when available. Also see
see Regulations section 1.832-4(d)
taxable income” and “adjusted net
Regulations section 1.832-4.
regarding increasing unpaid losses shown
operating loss” mean the taxable income
Line 9. Tax-exempt interest subject to
on the annual statement by salvage
or the net operating loss, respectively,
section 832(b)(5)(B). Enter the amount
recoverable. Also see Rev. Proc. 92-77,
determined with the following
of tax-exempt interest received or
1992-2 C.B. 454.
modifications:
accrued during the tax year on
The applicable interest rate for each
1. Without regard to the deduction
investments made after August 7, 1986.
calendar year and the applicable loss
determined under section 833(b)(1);
For information regarding the
payment pattern for each accident year
2. Without regard to any carryover or
determination of the acquisition date of an
for each line of business are determined
carryback to that tax year; and
investment, see the instructions for
by the IRS. The applicable interest rate
3. By increasing gross income by an
Schedule C.
and loss payment patterns for 2005 are
amount equal to the net exempt income
published in Rev. Proc. 2005-72, 2005-49
for the tax year.
I.R.B. 1078. The applicable interest rates
Schedule G—Other
and loss payment pattern for 2003 and
Line 6. Special deduction. The
Capital Losses
2004 are published in Rev. Proc. 2004-9,
deduction for any tax year is limited to
taxable income for that tax year
2004-2 I.R.B. 275, and Rev. Proc.
Capital assets are considered sold or
determined without regard to this
2004-69, 2004-49 I.R.B. 906,
exchanged to provide funds to meet
deduction.
respectively.
abnormal insurance losses and to pay
Corporations having sufficient
dividends and make similar distributions
Note. Under section 833(b)(4), any
historical experience to determine a loss
to policyholders to the extent that the
determination under section 833(b) must
payment pattern may, under certain
gross receipts from their sale or exchange
be made by only taking into account items
-18-
Instructions for Form 1120-PC

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