IRS issues final salvage and subrogation regulations

Article Abstract:

New IRS rules will allow insurance taxpayers to include loss reserves for anticipated salvage on their tax returns. The regulations also place restrictions on the special deduction for estimated salvage granted by the 1990 Tax Act, and they address the issue of life/nonlife consolidated tax returns. In addition, the IRS has ruled that insurers can not use the results of a 1987 arbitration decision to increase tax deductions for losses that occurred in 1986.

INSURANCE CARRIERS, Taxation, Laws, regulations and rules, Insurance industry, Subrogation

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IRS appeals to a higher court but does not win its case

Article Abstract:

The 7th US Circuit of Appeals has ruled on insurance arrangements with substance dependent on tax purposes. The case involved Sears Roebuck and Co's insurance agreements with its Allstate Insurance Co unit. Allstate subsidiary PMI Mortgage Insurance Co, which underwrote the policies, established estimated reserves for losses. The IRS felt that the deductions should have been made after actual loss is experienced, and the appeals court concurred.

Department stores, Life insurance, Finance, taxation, & monetary policy, Fire, marine, and casualty insurance, Interpretation and construction, Cases, Allstate Insurance Co., Sears, Roebuck and Co., S, United States. Internal Revenue Service, Insurance law

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