ASG Rules

[jpod]

The IRS' proposed regulations lists certain fields that will automatically be considered as service organizations, even if capital is a material income producing factor, one of which is "insurance." Is an organization that is a licensed insurance company that is in the business of issuing insurance included within the meaning of the "insurance" field on that list? I am asking because an insurance company is buying less than 80% of a service organization, so there is no 414(b) or © affiliation, and they will satisfy the other criteria for A Organization ASG status, but the point is moot unless the licensed incurance company is a "service organization."