ඇය තවම තරුනයි 6
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The retrospective premiums were determined six months after the coverage period and annually thereafter until all claims were satisfied or until the taxpayer and the insurance company agreed to a final retrospective premium.One of the factors that influenced the retrospective premium after the first determination date was the actual loss payments made by the insurer.
The Service bifurcated the taxpayer's premium payments into a deductible insurance component and a non-deductible "reserve for losses" component. It indicated that, "no risk of loss [was] shifted or distributed by the taxpayer to the extent that the amount payable by taxpayer to the insurance company is based on the actual losses of taxpayer during the period covered by the arrangement" so that the taxpayer could not deduct the component of premium payments based on such losses.
The Service distinguished the retrospective rated contracts from retrospectively rated contracts addressed in Revenue Ruling 83-66,189 in which a medical malpractice insurance policy provided a retrospective rate credit refund if the insurer's overall loss experience was not as great as it projected.190 The retrospective credits in the 1983 ruling were based on the insurance company's experience whereas the amounts ultimately payable by the manufacturer in the technical advice were based, in part, on its own loss experience for its policy year.
