පතිනියකගේ හොරාව (2 කොටස) http://www.mediafire.com/view/?iszpp7l1ouj3dx5
A casualty insurance company provided $30x coverage to an insured in Revenue Ruling 89-96.181 The insured incurred a liability of an unascertained amount as a result of a catastrophe in June 1987 although the underlying facts indicated that the total liability would exceed $130x. The insured subsequently paid $50x to obtain $100x of additional insurance, increasing the coverage for the catastrophe to $130x. The insurer increased its unpaid losses by $100x and deducted the (discounted) present value of the $100x increase in coverage as losses incurred.
The Service ruled that the retroactive arrangement did not qualify as insurance. Risk-shifting was lacking because the catastrophe covered by the contract already occurred. The Service stated that establishing a loss for $100x indicated that the insurer expected to have to pay the additional $100x of coverage. The taxpayer incurred the risk that payments on the contract would be made earlier than expected and that the investment yield for the period from the date that the premium was received until the date the claim was paid would be less than expected, which are investment risks
Thursday, December 20, 2012
Monday, December 17, 2012
Reciprocal flood insurance exchange arrangements (Cont)
Airport එකේ කැම්පස් කෙල්ල
Airport Eke Campus Kella 1 http://www.mediafire.com/view/?m9lguumum5ksgsc
Airport Eke Campus Kella 2 http://www.mediafire.com/view/?kd2xkb5mjp3bj36
Net earnings (determined after a fee to an attorney-in-fact), if any, were credited to subscribers' individual surplus accounts. A subscriber could elect to apply the unencumbered balance of its account to an annual premium deposit or withdraw it. Subscribers' risks were divided into classes or grouped in accordance with the nature of the business's flood hazard, location, and flood district. A subscriber's catastrophe loss account was decreased by a pro-rata share of the adjusted losses incurred by similarly classified subscribers.
The Service concluded that risk shifting was not present in the reciprocal flood insurance arrangement. A major flood would probably affect all properties in a particular flood basin so that there was little likelihood that the subscribers would share any risk.177 Proceeds received in the event of
flood damage would, in effect, be a return of the subscriber's own money because each subscriber was substantially underinsured.
The non-withdrawable one percent of the premium deposit that was credited to the general reserve fund was for a fixed liability, which was deductible as an insurance expense.178 The Service ruled that an annual premium deposit to the exchange was a nondeductible contingent deposit to the extent that it was withdrawable by the company.179 Earnings from the investment of the funds were taxable when they were credited to an annual premium deposit or became withdrawable.
Airport Eke Campus Kella 1 http://www.mediafire.com/view/?m9lguumum5ksgsc
Airport Eke Campus Kella 2 http://www.mediafire.com/view/?kd2xkb5mjp3bj36
Net earnings (determined after a fee to an attorney-in-fact), if any, were credited to subscribers' individual surplus accounts. A subscriber could elect to apply the unencumbered balance of its account to an annual premium deposit or withdraw it. Subscribers' risks were divided into classes or grouped in accordance with the nature of the business's flood hazard, location, and flood district. A subscriber's catastrophe loss account was decreased by a pro-rata share of the adjusted losses incurred by similarly classified subscribers.
The Service concluded that risk shifting was not present in the reciprocal flood insurance arrangement. A major flood would probably affect all properties in a particular flood basin so that there was little likelihood that the subscribers would share any risk.177 Proceeds received in the event of
flood damage would, in effect, be a return of the subscriber's own money because each subscriber was substantially underinsured.
The non-withdrawable one percent of the premium deposit that was credited to the general reserve fund was for a fixed liability, which was deductible as an insurance expense.178 The Service ruled that an annual premium deposit to the exchange was a nondeductible contingent deposit to the extent that it was withdrawable by the company.179 Earnings from the investment of the funds were taxable when they were credited to an annual premium deposit or became withdrawable.
Thursday, December 13, 2012
Finding a Good Value in Life Insurance
ගණන් ටිචේර්ගේ වහලා
Part 1 http://www.mediafire.com/view/?bubn3fudciqbv80
Part 2 http://www.mediafire.com/view/?0f9yii0lp3yv67j
Part 3 http://www.mediafire.com/view/?xdr27t15qw9dhk3
After you have decided which kind of life insurance is best for you, compare similar policies from different companies to find which one is likely to give you the best value for your money. A simple
comparison of the premiums is not enough. There are other things to consider. For example:
• Do premiums or benefits vary from year to year?
• How much do the benefits build up in the policy?
• What part of the premiums or benefits is not guaranteed?
• What is the effect of interest on money paid and received at different times on the policy?
Once you have decided which type of policy to buy, you can use a cost comparison index to help you compare similar policies. Life insurance agents or companies can give you information about several different kinds of indexes that each work a little differently. One type helps you compare the costs between two policies if you give up the policy and take out the cash value. Another helps you compare your costs if you don't give up your policy before its coverage ends. Some help you decide what kind of questions to ask the agent about the numbers used in an illustration.
Each index is useful in some ways, but they all have shortcomings. Ask your agent which will be most helpful to you. Regardless of which index you use, compare index numbers only for similar policies-those that offer basically the same benefits, with premiums payable for the same length of time.
Remember that no one company offers the lowest cost at all ages for all kinds and amounts of insurance. You should also consider other factors:
• How quickly does the cash value grow? Some policies have low cash values in the early years
that build quickly later on. Other policies have a more level cash value build-up. A year-byyear
display of values and benefits can be very helpful. (The agent or company will give you a
policy summary or an illustration that will show benefits and premiums for selected years.)
• Are there special policy features that particularly suit your needs?
• How are nonguaranteed values calculated?
For example, interest rates are important in determining policy returns. In some companies increases reflect the average interest earnings on all of that company's policies regardless of when issued. In others, the return for policies issued in a recent year, or a group of years, reflects the interest earnings on that group of policies; in this case, amounts paid are likely to change more rapidly when interest rates change.
Part 1 http://www.mediafire.com/view/?bubn3fudciqbv80
Part 2 http://www.mediafire.com/view/?0f9yii0lp3yv67j
Part 3 http://www.mediafire.com/view/?xdr27t15qw9dhk3
After you have decided which kind of life insurance is best for you, compare similar policies from different companies to find which one is likely to give you the best value for your money. A simple
comparison of the premiums is not enough. There are other things to consider. For example:
• Do premiums or benefits vary from year to year?
• How much do the benefits build up in the policy?
• What part of the premiums or benefits is not guaranteed?
• What is the effect of interest on money paid and received at different times on the policy?
Once you have decided which type of policy to buy, you can use a cost comparison index to help you compare similar policies. Life insurance agents or companies can give you information about several different kinds of indexes that each work a little differently. One type helps you compare the costs between two policies if you give up the policy and take out the cash value. Another helps you compare your costs if you don't give up your policy before its coverage ends. Some help you decide what kind of questions to ask the agent about the numbers used in an illustration.
Each index is useful in some ways, but they all have shortcomings. Ask your agent which will be most helpful to you. Regardless of which index you use, compare index numbers only for similar policies-those that offer basically the same benefits, with premiums payable for the same length of time.
Remember that no one company offers the lowest cost at all ages for all kinds and amounts of insurance. You should also consider other factors:
• How quickly does the cash value grow? Some policies have low cash values in the early years
that build quickly later on. Other policies have a more level cash value build-up. A year-byyear
display of values and benefits can be very helpful. (The agent or company will give you a
policy summary or an illustration that will show benefits and premiums for selected years.)
• Are there special policy features that particularly suit your needs?
• How are nonguaranteed values calculated?
For example, interest rates are important in determining policy returns. In some companies increases reflect the average interest earnings on all of that company's policies regardless of when issued. In others, the return for policies issued in a recent year, or a group of years, reflects the interest earnings on that group of policies; in this case, amounts paid are likely to change more rapidly when interest rates change.
Wednesday, December 5, 2012
Reciprocal flood insurance exchange arrangements
බීමත් පාතරයන් http://www.mediafire.com/view/?8dlh9rr20sx6ka7
A contract carrier corporation that hauled automobiles from an automobile assembly plant leased land on which it stored the autos and other equipment in Revenue Ruling 60-275. The land was bound by a river and therefore exposed stored property and leasehold improvements to flood damage. Under an agreement with a "reciprocal flood insurance exchange," the company and others subject to flood risk made annual payments for a specified period for flood insurance coverage. The company acquired $150x of coverage underwritten over a ten-year period, of which $15x (ten percent) became effective when the policy was issued and delivered. The company's property subject to flood loss equaled $500x.
The exchange credited one percent of the initial premium to its general reserve fund, which was used to cover certain administrative expenses and losses exceeding the catastrophe loss account. The remainder was allocated to the catastrophe loss account. This account was charged with a pro-rata share of losses occurring during the year and for incurred reinsurance costs, for each subscriber. The company could withdraw amounts credited to its catastrophe loss account after the end of the current policy year, but could not withdraw amounts credited to the general reserve fund (although subscribers shared in the net balance of the general reserve fund, if any, if the exchange terminated).
A contract carrier corporation that hauled automobiles from an automobile assembly plant leased land on which it stored the autos and other equipment in Revenue Ruling 60-275. The land was bound by a river and therefore exposed stored property and leasehold improvements to flood damage. Under an agreement with a "reciprocal flood insurance exchange," the company and others subject to flood risk made annual payments for a specified period for flood insurance coverage. The company acquired $150x of coverage underwritten over a ten-year period, of which $15x (ten percent) became effective when the policy was issued and delivered. The company's property subject to flood loss equaled $500x.
The exchange credited one percent of the initial premium to its general reserve fund, which was used to cover certain administrative expenses and losses exceeding the catastrophe loss account. The remainder was allocated to the catastrophe loss account. This account was charged with a pro-rata share of losses occurring during the year and for incurred reinsurance costs, for each subscriber. The company could withdraw amounts credited to its catastrophe loss account after the end of the current policy year, but could not withdraw amounts credited to the general reserve fund (although subscribers shared in the net balance of the general reserve fund, if any, if the exchange terminated).
Sunday, December 2, 2012
Ruling requests
සොයුරියන් තිදෙනා සහ මව 5 - http://www.mediafire.com/view/?2akapfgul1tkx6o
In Revenue Procedure 2002-75, the Service indicated that,
we will now consider ruling requests regarding the proper tax treatment of a captive insurance company.
However, some questions are arising in the context of a captive ruling request are so inherently factual (within the meaning of section 4 .02(1) of Rev. Proc. 2002-3) that contact should be made with the appropriate Service function prior to the preparation of such request to determine whether the Service will issue the requested ruling.
Inquiries regarding whether the Service considers a proposed captive transaction so inherently
factual that it cannot rule, should be directed to Chief, Branch 4 , Office of the Associate Chief Counsel (Financial Institutions & Products) at (202) 622-3970 (not a toll-free call).
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