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(applying from years 1959 through 1983) and 813 of the Internal
Revenue Code of 1954, as amended, and section 813 of the Internal
Revenue Code of 198614 (applying from years 1984 through 1987).
13(...continued)
(B) the means of the amount of such reserves
computed at that rate at the beginning and end of
the taxable year.
The Life Insurance Company Income Tax Act of 1959, Pub. L. 86-69,
sec. 2, 73 Stat. 136, added sec. 819(b), which required the same
adjustment as sec. 819(a) except that the minimum figure was
determined by multiplying the foreign life insurance company's
total insurance liabilities on U.S. business by 9 percent for
tax years beginning before January 1, 1959 and by an annual
percentage determined by the Treasury for tax years thereafter.
The Foreign Investors Act of 1966, Pub. L. 89-809, sec. 104,
104(i)(3), 80 Stat. 1539, 1561, redesignated the adjustment
provision as sec. 819(a) for tax years beginning after 1966.
From 1966 until 1983, sec. 819(a) remained unchanged except for
minor changes, which are not relevant to the instant case.
14Sec. 813 provided in pertinent part:
(a) Adjustment where surplus held in the United States
is less than specified minimum--
(1) In general.--In the case of any foreign company
taxable under this part, if--
(A) the required surplus determined under
paragraph (2), exceeds
(B) the surplus held in the United States,
then its income effectively connected with the conduct
of an insurance business within the United States shall
be increased by an amount determined by multiplying
such excess by such company's current investment yield.
* * *
(2) Required surplus.--For purposes of this subsection--
(A) In general.--The term "required surplus" means
(continued...)
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