26 U.S. Code § 845 - Certain reinsurance agreements
If the Secretary determines that any reinsurance contract has a significant tax avoidance effect on any party to such contract, the Secretary may make proper adjustments with respect to such party to eliminate such tax avoidance effect (including treating such contract with respect to such party as terminated on December 31 of each year and reinstated on January 1 of the next year).
2004—Subsec. (a). Pub. L. 108–357 substituted “amount, source, or character” for “source and character” in concluding provisions.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
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- Allocation of Income and Deductions Among Taxpayers : 2000-07-07
- Certain Reinsurance Agreements : 2000-07-07
- Allocation of Income and Deductions Among Taxpayers : 2000-06-30
- Certain Reinsurance Agreements : 2000-06-30
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