නිවාඩුව - http://www.mediafire.com/view/?z2a0es2b14tl3zb
The Service addressed whether certain vehicle service agreements
(VSAs) that provided coverage for the mechanical breakdown of certain
new and used motor vehicles were insurance contracts or prepaid service
contracts in Letter Ruling 200509005. A company proposed to issue contracts
that would provide coverage that exceeded the amount provided by
a manufacturer or a guarantee provided by a repairer. Salesmen at motor
vehicle dealerships, acting as agents for the company, would sell the contracts,
retain a portion of the sales price as a commission, and remit the
remainder to the company.
The company paid fees to a third party administrator with expertise
in adjudicating mechanical breakdown claims, and to a licensed insurance
company that would indemnify purchasers of the vehicle service agreements
if the company defaulted. The company allocated the remaining
proceeds to a custodial account in its name as reserves, which were used
to pay claims under the vehicle service agreements. The company did
not manufacture, sell or service the motor vehicles covered by the agreements.
