Internal Revenue Service January 23, 2008 – Federal Register Recent Federal Regulation Documents
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Application of Section 338 to Insurance Companies
This document contains final regulations under section 197 of the Internal Revenue Code (Code) that apply to a section 197 intangible resulting from an assumption reinsurance transaction, and under section 338 that apply to reserve increases after a deemed asset sale. The final regulations also provide guidance with respect to existing section 846(e) elections to use historical loss payment patterns. The final regulations apply to insurance companies.
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