- 50 - The agreement, with respect to OPL's reinsurance of Liberty Mutual includes but is not limited to the following terms: 1. OPL reinsured Liberty Mutual's UPS California workers' compensation exposure for losses not exceeding $250,000 from any one accident. Liberty Mutual retained the exposure for losses exceeding $250,000 from any one accident. Liberty Mutual also retained the risk of multiple accidents with losses in excess of $250,000. 2. Liberty Mutual Fire agreed to pay over to OPL an amount equal to the premiums received on the California workers compensation policy, less $50,000 for the retained layer of liability for losses above $250,000, a management fee equal to 1 percent of the premium, 1 percent of the premium for excise tax, and a ceding commission equal to 12 percent of the losses incurred. The ceding commission was capped at $1.2 million. 3. Liberty Mutual retained the obligation to investigate and adjust all claims for the UPS workers' compensation program in California. 4. Liberty Mutual paid a 1 percent excise tax on reinsurance by a foreign insurer, pursuant to I.R.C. section 4371. C. Amount in Dispute On its 1984 Federal income tax return, petitioner deducted the estimated premium of $14,241,915 it paid to Liberty MutualPage: Previous 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 Next
Last modified: May 25, 2011