Instructions For Form 1120-Pc - 2009 Page 18

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recoverable. Also see Rev. Proc. 92-77,
For information regarding the
3. By increasing gross income by an
1992-2 C.B. 454.
determination of the acquisition date of an
amount equal to the net exempt income
investment, see the instructions for
for the tax year.
The applicable interest rate for each
Schedule C.
calendar year and the applicable loss
Line 6. Special deduction. The
payment pattern for each accident year
deduction for any tax year is limited to
for each line of business are determined
taxable income for that tax year
Schedule G—Other
by the IRS. The applicable interest rate
determined without regard to this
and loss payment patterns for 2009 are
Capital Losses
deduction.
published in Rev. Proc. 2009-55, 2009-52
Note. Under section 833(b)(4), any
Capital assets are considered sold or
I.R.B. 982. The applicable interest rate
determination under section 833(b) must
exchanged to provide funds to meet
and loss payment patterns for 2007 and
be made by only taking into account items
abnormal insurance losses and to pay
2008 are published in Rev. Proc.
from the health-related business of the
dividends and make similar distributions
2008-10, 2008-3 I.R.B. 290, and Rev.
corporation.
to policyholders to the extent that the
Proc. 2008-70, 2008-49 I.R.B. 1240,
gross receipts from their sale or exchange
respectively.
Line 8a. Adjusted tax-exempt income.
are not more than the amount by which
Reduce the total tax-exempt interest
Corporations having sufficient
the sum of dividends and similar
received or accrued during the tax year
historical experience to determine a loss
distributions paid to policyholders, losses
by any amount (not otherwise deductible)
payment pattern may, under certain
paid, and expenses paid for the tax year
which would have been allowable as a
circumstances, elect under section 846(e)
is more than the total on line 9, Schedule
deduction for the tax year if such interest
to use their own historical experience
G.
were not tax-exempt. Enter the result on
(instead of the loss payment patterns
line 8a.
determined by the IRS). If this election is
Total gross receipts from sales of
made, the loss payment patterns will be
capital assets (line 12, column (c)) must
Line 8b. Adjusted dividends-received
based on the most recent calendar year
not be more than line 10. If necessary,
deduction. Reduce the total amount
for which an annual statement was filed
the corporation may report part of the
allowed as a deduction under sections
before the beginning of the accident year.
gross receipts from a particular sale of a
243, 244, and 245 by the amount of any
The election will not apply to any
capital asset on this schedule and the rest
decrease in deductions allowable for the
international or reinsurance line of
on Schedule D (Form 1120). Otherwise,
tax year because of section 832(b)(5)(B)
business. If the corporation makes this
do not include on Schedule D (Form
when the decrease is caused by the
election, check the “Yes” column for
1120) any sales reported on this
deductions under sections 243, 244, and
question 7 in Schedule I, Other
schedule.
245. Enter the result on line 8b.
Information. For more information, see
section 846(e), Regulations section
1.846-2, and Rev. Proc. 92-76, 1992-2
Schedule I—Other
Schedule H—Special
C.B. 453.
Information
Deduction and Ending
Note. There is a special application of
The following instructions apply to page 7,
the “fresh start” provision for an insurance
Adjusted Surplus for
Form 1120-PC. Complete all items that
company that is not subject to tax under
Section 833 Organizations
apply to the corporation.
section 831(a) for its first tax year
beginning after December 31, 1986,
Line 5. Beginning adjusted surplus. If
Question 4
because (1) it is described in section
the corporation was a section 833
Check the “Yes” box if:
501(c) or (2) it is subject to tax under
organization in 2008, it should enter the
The corporation is a subsidiary in an
section 831(b) on its investment income.
amount from Schedule H, line 10, of its
affiliated group (defined below), but is not
If the insurance company later
2008 Form 1120-PC.
filing a consolidated return for the tax year
becomes subject to tax under section
with that group, or
Generally, the adjusted surplus as of
831(a), the rules relating to the fresh start
The corporation is a subsidiary in a
the beginning of any tax year is an
under the discounting provisions are
parent-subsidiary controlled group. For a
amount equal to the adjusted surplus as
applied by treating the last tax year before
definition of parent-subsidiary controlled
of the beginning of the preceding tax
the year in which the insurance company
group, see the instructions for Schedule
year:
becomes subject to tax under section
O (Form 1120).
1. Increased by the amount of any
831(a) as the insurance company’s last
Any corporation that meets either of
adjusted taxable income for the preceding
tax year beginning before 1987. See
the requirements above should check the
tax year or
section 1010(e) of the Technical and
“Yes” box. This applies even if the
2. Decreased by the amount of any
Miscellaneous Revenue Act of 1988 and
corporation is a subsidiary member of one
adjusted net operating loss for the
Notice 88-100, 1988-2 C.B. 439.
group and the parent corporation of
preceding tax year.
Lines 6 and 7. Estimated salvage and
another.
reinsurance recoverable. Enter on
If 2009 is the first tax year the taxpayer
Note. If the corporation is an “excluded
lines 6 and 7 the amount of estimated
qualifies as a section 833 organization,
member” of a controlled group (see
salvage and reinsurance recoverable.
see section 833(c)(3)(C) to determine the
definition in the Instructions for Schedule
The amount of estimated salvage
adjusted surplus as of the beginning of
O (Form 1120)), it is still considered a
recoverable must be determined on a
the 2009 tax year.
member of a controlled group for this
discounted basis. The salvage discount
purpose.
factors for 2009 are published in Rev.
For purposes of the computation of the
Proc. 2009-56, 2009-52 I.R.B. 993. The
adjusted surplus, the terms “adjusted
Affiliated group. An affiliated group is
salvage discount factors for 2010 will be
taxable income” and “adjusted net
one or more chains of includible
published in the Internal Revenue Bulletin
operating loss” mean the taxable income
corporations (section 1504(a)) connected
when available. Also see Regulations
or the net operating loss, respectively,
through stock ownership with a common
section 1.832-4.
determined with the following
parent corporation. The common parent
modifications:
must be an includible corporation and the
Line 9. Tax-exempt interest subject to
following requirements must be met.
section 832(b)(5)(B). Enter the amount
1. Without regard to the deduction
of tax-exempt interest received or
determined under section 833(b)(1);
1. The common parent must own
accrued during the tax year on
2. Without regard to any carryover or
directly stock that represents at least 80%
investments made after August 7, 1986.
carryback to that tax year; and
of the total voting power and at least 80%
-18-
Instructions for Form 1120-PC (2009)

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