අම්ම සහ අක්කල 3 දෙනා
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A company may pay premiums to a related insurer
to cover other persons’ risks. In Revenue Ruling
92-93,
a manufacturer paid
premiums to a subsidiary insurance company for
group-term life insurance coverage for its employees.
The Service concluded that the arrangement was
not self-insurance because the manufacturer did not
incur the underlying economic risk of
loss.
The economic benefit
was enjoyed by the employees, not the employer, which
could not be the beneficiary under the contract. The
arrangement, in effect, was a form of compensation for
the taxpayer’s employees, who benefited from the life
insurance coverage.
The Service ruled
that similar principles would apply to the acquisition of accident and health insurance, including waiver of premium
coverage upon disability that was provided by an
employer for its employees. The Service applied similar principles in
Revenue Ruling 92-94 to a nonlife insurance company
that “charges itself an amount representing
premiums for its liability to pay insurance
or annuity benefits for its
employees.”
