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* Front Fee 2.0
Premium Tax 3.5%
Federal Excise Tax 1.0%
6.5%
The $16,077,500 projected benefit to petitioner is the amount of
Federal income tax petitioner would have otherwise paid and is
based on the assumption that the underwriting profit, which was
referred to as the "UPS Insurance Subsidiary" in Bermuda, would
not be subject to Federal income tax.
(2) AIG/NUF
American International Group, Inc. (AIG), was a holding
company and the parent of over 500 subsidiary operating insurance
and subsidiary companies. AIG Risk Management, Inc. (AIGRM), was
a subsidiary of AIG. Mr. Joseph Smetana served as president and
CEO of AIGRM and senior vice president of NUF. NUF was a wholly
owned subsidiary of AIG and operated as a domestic insurance
company.
On behalf of Hall, through a letter dated April 27, 1983,
Mr. Corde contacted Mr. Smetana. In the letter, Mr. Corde
apprised Mr. Smetana of petitioner's plan regarding the EVC's.
Mr. Corde indicated in the letter that petitioner's plan
contemplated that the shippers' property handled by petitioner
would be insured under a master "Shippers Interest Policy".
Further, the letter indicated that the contract of insurance
would be issued to petitioner and would cover the property of the
owners, shippers, consignees, or other interested parties. With
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