- 12 - contained in both the Senate bill and in the accompanying Senate Finance Committee report. The Senate bill contained the following provision: (B) Reserve Strengthening After March 1, 1986.-- * * * [the fresh start provision] shall not apply to any reserve strengthening reported for Federal income tax purposes after March 1, 1986, for a taxable year beginning before January 1, 1987, and such strengthening shall be treated as occurring in the taxpayer's 1st taxable year beginning after December 31, 1986. The preceding sentence shall not apply to the computation of reserves on any contract if such computation employs the reserve practice used for purposes of the most recent annual statement filed on or before March 1, 1986, for the type of contract with respect to which such reserves are set up. [H.R. 3838, 99th Cong., 2d Sess., sec. 1022(e)(3)(B), as reported by the Senate Finance Committee on May 29, 1986.] The Finance Committee report stated that "reserve strengthening" consisted of "any adjustments to reserves that are attributable to changes in reserves on account of changes in the basis for computing reserves (i.e., reserve strengthening or reserve weakening) in a taxable year beginning before January 1, 1987". S. Rept. 99-313, supra at 510, 1986-3 C.B. (Vol. 3) at 510. The differences between the House and Senate versions of H.R. 3838 were reconciled by the conference committee. The final bill adopted by the conference committee and enacted into law did not define "reserve strengthening". It provided as follows: (B) Reserve Strengthening In Years After 1985.-- * * * [the fresh start provision] shall not apply to any reserve strengthening in a taxable year beginning in 1986, and such strengthening shall be treated as occurring in the taxpayer's 1st taxable year beginningPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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