Final regulations and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2008-01-23
Effective date
2008-01-23
Treasury docket
TD 9377
Abstract
This document contains final regulations under section 197 of the Internal Revenue Code (Code) that apply to a section 197 intangible resulting from an assumption reinsurance transaction, and under section 338 that apply to reserve increases after a deemed asset sale. The final regulations also provide guidance with respect to existing section 846(e) elections to use historical loss payment patterns. The final regulations apply to insurance companies.