Instructions For Form 1120-Pc - U.s. Property And Casualty Insurance Company Income Tax Return Page 18

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Line 8b. Adjusted dividends-received
section 846(e), Regulations section
Schedule H—Special
deduction. Reduce the total amount
1.846-2, and Rev. Proc. 92-76, 1992-2
allowed as a deduction under sections
C.B. 453.
Deduction and Ending
243, 244, and 245 by the amount of any
Note. There is a special application of
Adjusted Surplus for
decrease in deductions allowable for the
the “fresh start” provision for an insurance
tax year because of section 832(b)(5)(B)
Section 833 Organizations
company that is not subject to tax under
when the decrease is caused by the
section 831(a) for its first tax year
deductions under sections 243, 244, and
Section 833(c)(5) provides that section
beginning after December 31, 1986,
245. Enter the result on line 8b.
833 does not apply to any organization
because (1) it is described in section
with a medical loss ratio of less than 85%.
501(c) or (2) it is subject to tax under
See section 833(c)(5) and Notice 2010-79
section 831(b) on its investment income.
Schedule I—Other
for more information.
If the insurance company later
Information
Line 5. Beginning adjusted surplus. If
becomes subject to tax under section
the corporation was a section 833
The following instructions apply to page 7,
831(a), the rules relating to the fresh start
organization in 2010, it should enter the
Form 1120-PC. Complete all items that
under the discounting provisions are
amount from Schedule H, line 10, of its
apply to the corporation.
applied by treating the last tax year before
2010 Form 1120-PC.
the year in which the insurance company
Question 4
Generally, the adjusted surplus as of
becomes subject to tax under section
Check the “Yes” box if:
the beginning of any tax year is an
831(a) as the insurance company’s last
The corporation is a subsidiary in an
amount equal to the adjusted surplus as
tax year beginning before 1987. See
affiliated group (defined below), but is not
of the beginning of the preceding tax
section 1010(e) of the Technical and
filing a consolidated return for the tax year
year:
Miscellaneous Revenue Act of 1988 and
with that group, or
Notice 88-100, 1988-2 C.B. 439.
1. Increased by the amount of any
The corporation is a subsidiary in a
adjusted taxable income for the preceding
parent-subsidiary controlled group. For a
Lines 6 and 7. Estimated salvage and
tax year or
definition of parent-subsidiary controlled
reinsurance recoverable. Enter on
2. Decreased by the amount of any
group, see the instructions for Schedule
lines 6 and 7 the amount of estimated
adjusted net operating loss for the
O (Form 1120).
salvage and reinsurance recoverable.
preceding tax year.
The amount of estimated salvage
Any corporation that meets either of
recoverable must be determined on a
the requirements above should check the
If 2011 is the first tax year the taxpayer
discounted basis. The salvage discount
“Yes” box. This applies even if the
qualifies as a section 833 organization,
factors for 2011 are published in Rev.
corporation is a subsidiary member of one
see section 833(c)(3)(C) to determine the
Proc. 2011-54, 2011-46 I.R.B . 759. The
group and the parent corporation of
adjusted surplus as of the beginning of
salvage discount factors for 2012 will be
another.
the 2011 tax year.
published in the Internal Revenue Bulletin
Note. If the corporation is an “excluded
For purposes of the computation of the
when available. Also see Regulations
member” of a controlled group (see
adjusted surplus, the terms “adjusted
section 1.832-4.
definition in the Instructions for Schedule
taxable income” and “adjusted net
O (Form 1120)), it is still considered a
Line 9. Tax-exempt interest subject to
operating loss” mean the taxable income
member of a controlled group for this
section 832(b)(5)(B). Enter the amount
or the net operating loss, respectively,
purpose.
of tax-exempt interest received or
determined with the following
accrued during the tax year on
Affiliated group. An affiliated group is
modifications:
investments made after August 7, 1986.
one or more chains of includible
1. Without regard to the deduction
For information regarding the
corporations (section 1504(a)) connected
determined under section 833(b)(1);
determination of the acquisition date of an
through stock ownership with a common
2. Without regard to any carryover or
investment, see the instructions for
parent corporation. The common parent
carryback to that tax year; and
Schedule C.
must be an includible corporation and the
3. By increasing gross income by an
following requirements must be met.
amount equal to the net exempt income
1. The common parent must own
for the tax year.
Schedule G—Other
directly stock that represents at least 80%
of the total voting power and at least 80%
Line 6. Special deduction. The special
Capital Losses
of the total value of the stock of at least
deduction under section 833(b) cannot be
Capital assets are considered sold or
one of the other includible corporations.
taken if the medical loss ratio is less than
exchanged to provide funds to meet
2. Stock that represents at least 80%
85%. If the medical loss ratio is less than
abnormal insurance losses and to pay
of the total voting power and at least 80%
85%, enter zero on line 6 and Schedule
dividends and make similar distributions
of the total value of the stock of each of
A, line 34a.
to policyholders to the extent that the
the other corporations (except for the
Note. The deduction for any tax year is
gross receipts from their sale or exchange
common parent) must be owned directly
limited to taxable income for that tax year
are not more than the amount by which
by one or more of the other includible
determined without regard to this
the sum of dividends and similar
corporations.
deduction.
distributions paid to policyholders, losses
For this purpose, the term “stock”
paid, and expenses paid for the tax year
Note. Under section 833(b)(4), any
generally does not include any stock that
is more than the total on line 9, Schedule
determination under section 833(b) must
(a) is nonvoting, (b) is nonconvertible, (c)
G.
be made by only taking into account items
is limited and preferred as to dividends
from the health-related business of the
Total gross receipts from sales of
and does not participate significantly in
corporation.
capital assets (line 12, column (c)) must
corporate growth, and (d) has redemption
not be more than line 10. If necessary,
Line 8a. Adjusted tax-exempt income.
and liquidation rights that do not exceed
the corporation may report part of the
Reduce the total tax-exempt interest
the issue price of the stock (except for a
gross receipts from a particular sale of a
received or accrued during the tax year
reasonable redemption or liquidation
capital asset on this schedule and the rest
by any amount (not otherwise deductible)
premium). See section 1504(a)(4).
on Schedule D (Form 1120). Otherwise,
which would have been allowable as a
Question 6
do not include on Schedule D (Form
deduction for the tax year if such interest
1120) any sales reported on this
were not tax-exempt. Enter the result on
Check the “Yes” box if one foreign person
schedule.
line 8a.
owned at least 25% of (a) the total voting
-18-
Instructions for Form 1120-PC (2011)

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