- 44 - (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...)Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 Next
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