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Text of IRS Chief Counsel Memo 20140201F on Treatment of Premium Stabilization Reserves (PDF)
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Jan. 14, 2014
"Issue: May positive balances in the Company's Experience Premium Stabilization Reserve (PSR) accounts be deducted from gross income under Section 832? Conclusion: The positive balances in the PSR are not return premiums and cannot be deducted from gross income under Section 832 until they are refundable to customers or creditable to customers' accounts. Because the Company's contracts at issue provide that positive PSR balances are not returned to a customer upon termination of the contract, the Company's liability for the amounts at issue is not fixed." [Dec. 3, 2013; published online Jan. 14, 2014]

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