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IRS Captive Insurance Private Letter Rulings,IRS Determination
Letters for Captive Insurance Companies, Captive Insurance Letter Rulings, IRS
Letter Rulings for Captive Insurance Companies, IRS Captive Insurance Letter
Rulings
WMS, LLC
encourages its clients to
strongly consider obtaining an
IRS Private Letter Ruling
for their
Captive Insurance Company
in order to
guarantee
the
tax treatment
their
Captive
will receive from the
IRS. WMS, LLC
is happy to act on our
client's behalf to request and obtain an IRS
Private Letter Ruling
for their
Captive. IRS Private
Letter Rulings
are written
determinations issued by the National Office of the Internal Revenue Service.
Private Letter Rulings
dealing with matters involving insurance are specifically issued by the Office
of Associate Chief Counsel for Financial Institutions & Products, located in
Washington, DC.
IRS Private Letter Rulings
interpret and apply tax law to a taxpayer's specific set of facts.
IRS Private Letter Rulings deal with pre-return filing transactions and are issued
directly to individual taxpayers at their request.
These written
determinations are completely binding on the IRS with regard to the taxpayer who
requested the ruling. An
IRS
Private Letter Ruling
guarantees the tax treatment the taxpayer will receive on the covered
transaction. Once a
Private Letter Ruling has been issued, it can not
be over turned by an IRS Examining or Field Agent, or
anyone at an IRS Field Office. This absolute protection is however, limited to
the taxpayer who obtained the
Private
Letter Ruling.
Pursuant to IRC section 6110(j)(3), a
Private Letter Ruling
may not be used or cited as precedent. This means that every taxpayer must
individually request their own
Private Letter Ruling
from the IRS even if their fact pattern is virtually identical to the fact
pattern of a taxpayer who has already received a
Private Letter Ruling
from the IRS.
IRC section
6110 also provides that all names, addresses and taxpayer identification numbers
are required to be deleted from the copy of the
Private Letter Ruling that will
be open to public inspection.
The IRS imposes a
User Fee for each taxpayer request for a
Private Letter Ruling. The
User Fee is typically $10,000
for each Private Letter Ruling Request. In cases where multiple taxpayers are all involved in the same
transaction, or transactions which are "Substantially
Identical" the IRS User Fee is
$700 for each additional
Private Letter Ruling Request after the initial
$10,000 User Fee has been paid. For more
information on IRS User Fees for
obtaining an IRS Letter Rulings, please
Request for Free Consultation by filling out
and submitting the Form below.
On
December 30, 2002 in Internal
Revenue Bulletin 2002-52 the IRS issued Rev. Proc.
2002-75, which indicated that the IRS will provide guidance through
ruling letters on captive insurance companies relating to:
i. Whether there is
requisite risk shifting and risk distribution necessary to constitute
insurance for purposes of determining the deductibility of premiums as
ordinary and necessary business expenses: and
ii. Whether the requisite
risk shifting and risk distribution are present for determining whether an
entity is an insurance company for federal income tax purposes.
Listed below are three
Private Letter Rulings (PLR's)
which have
been issued to clients who have
Captive Insurance Companies.
You can also click on any of the Private Letter links for additional information
concerning IRS Private Letter Rulings, IRS Determination Letters and IRS Written
Determinations.
IRS PRIVATE RULING 200402001
(PDF version)
"This document
may not be used or cited as precedent. Section 6110(j)(3) of the Internal
Revenue Code."
Section 831 -- Tax on Other Insurance Companies
DATE: October 1, 2003
REFER REPLY TO: [*1] Refer Reply To: CC:FIP:4 -- PLR-135615-03
Release Date: 01/09/2004
Legend:
Taxpayer = * * *
State = * * *
Subsidiary = * * *
Company = * * *
Equipment A = * * *
Equipment B = * * *
Equipment C = * * *
Plan D = * * *
Plan E = * * *
Plan F = * * *
Amount 1 = * * *
Amount 2 = * * *
Amount 3 = * * *
Dear * * *:
[1] This is in reply to your letter of June 3, 2003, requesting rulings that the
contracts issued by Taxpayer's wholly owned subsidiary qualify as insurance
contracts for federal income tax purposes and that the subsidiary is taxable
under section 831 of the Internal Revenue Code as an insurance company other
than a life insurance company.
FACTS
[2] Based on the
representations made by Taxpayer, the relevant facts are as follows. Taxpayer is
a corporation chartered under the laws of State. Taxpayer uses the calendar year
as its taxable year and uses the accrual method of accounting for both its
financial records and for federal income tax purposes. Pursuant to section
1362(a), Taxpayer has elected to be an S corporation.
[3] Taxpayer produces Equipment A and Equipment B. Taxpayer provides Equipment A
and [*2] Equipment B to dealers in automobiles. These dealers install
Equipment A and Equipment B on automobiles they sell to retail customers.
Taxpayer has caused to be formed Subsidiary in State. The purpose of Subsidiary
is to offer extended service protection plans to customers purchasing Equipment
A and B, as well as offering an extended service protection plan covering
Equipment C, which is not produced by Taxpayer.
[4] With respect to Equipment A, Subsidiary will offer Plan D. If, while Plan D
is in force, Equipment A fails in the manner described in Plan D, Subsidiary
will pay the contract holder either Amount 1 or Amount 2, depending upon the
result of the failure. Subsidiary will reimburse the contract holder for
expenses incurred by the contract holder for travel (meals and lodging; airfare;
car rental) and for notification to family, business associates, and insurance
companies necessitated by the failure. Plan D also provides for a credit of
Amount 2 with the retail dealer who sold the contract holder the affected
automobile to be used by the contract holder towards the purchase of a
replacement automobile from that dealer.
[5] With respect to Equipment B, Subsidiary will offer [*3] Plan E. If, while
Plan E is in force, Equipment B fails in the manner described in Plan E,
Subsidiary will cause to have the resulting damage done to the automobile
repaired; however, Subsidiary's liability for damage done to the exterior of the
automobile is limited to the current value of the automobile as reflected in the
National Automobile Dealers Association Official Used Car Guide.
[6] With respect to Equipment C, Subsidiary will offer Plan F. If, while Plan F
is in force, Equipment C fails in the manner described in Plan F, Subsidiary
will cause to have Equipment C repaired or replaced, including installation. In
connection with this, Subsidiary will also provide, if appropriate, immediate
"roadside" assistance in an amount not to exceed Amount 3. Plan F excludes
coverage for more than one event during a seven day period.
[7] For all of the plans, the customer/contract holder pays only the
consideration agreed to at the time the plan is issued, and the consideration is
not returned to the customer/contract holder if no claim is made. Plan D is
non-cancelable and non-refundable. Plan F may be cancelled and if it is
cancelled a portion of the consideration will be returned to [*4] the contract
holder with the amount depending on how long the plan had been in force. Plan E
is silent regarding cancellation. None of the plans cover any consequential or
other damages suffered by the contract holder, except to the extent stated. The
coverage provided by the plans is not a substitute for any warranty made by the
manufacturer or seller of the equipment. Subsidiary will not perform any of the
repair work contemplated by the plans.
[8] All of the plans are administered and marketed by Taxpayer. Through
representatives of Taxpayer, Subsidiary will enter into arrangements with
automobile dealers under which the dealers offer for sale Plans D, E, and F.
Regardless of the price charged the contract holder for the plan, the dealer
must remit to Taxpayer a predetermined amount for each plan sold. Taxpayer will
retain a fee as compensation for its services and will remit the balance to
Subsidiary. Taxpayer will investigate and process all claims made under the
plans. When a claim under Plan E or F is approved by Taxpayer, Subsidiary will
reimburse the dealer or other authorized service provider for the parts and
labor required to perform the appropriate repair or replacement. [*5] When a
claim under Plan D is approved by Taxpayer, Subsidiary will pay the appropriate
benefit to the contract holder.
[9] In order to comply with applicable state regulation, and to facilitate the
conduct of its business, Subsidiary has entered into an agreement with Company,
a licensed insurance company, by which Company indemnifies Subsidiary in the
event Subsidiary is unable to perform its obligation(s) under the plans.
[10] Subsidiary will generate almost all of its revenue from the sale of the
plans since issuing the plans is its primary and predominant business activity.
LAW AND ANALYSIS
[11] Section 831(a) provides that taxes, as computed under section 11, will be
imposed on the taxable income (as defined by section 832) of each insurance
company other than a life insurance company.
[12] Section 1.831-3(a) of the Income Tax Regulations provides that, for
purposes of sections 831 and 832, the term "insurance companies" means only
those companies that qualify as insurance companies under the definition in
section 1.801-3(a)(1).
[13] Section 1.801-3(a)(1) provides that the term "insurance company" means a
company [*6] whose primary and predominant business activity during the taxable
year is the issuing of insurance or annuity contracts or the reinsuring of risks
underwritten by insurance companies. Section 1.801-3(a)(1) further provides that
though the company's name, charter powers, and subjection to state insurance
laws are significant in determining the business that a company is authorized
and intends to carry on, it is the character of the business actually done in
the taxable year that determines whether the company is taxable as an insurance
company under the Code. See also, Bowers v. Lawyers Mortgage Co., 285 U.S. 182,
188 (1932) (to the same effect as the regulation); Rev. Rul. 83-172, 1983-2 C.B.
107 (holding taxpayer was an insurance company as defined in section
1.801-3(a)(1), notwithstanding that taxpayer was not recognized as an insurance
company for state law purposes).
[14] Neither the Code nor the Regulations thereunder define the terms
"insurance" or "insurance contract". The accepted definition of "insurance" for
federal income tax purposes relates back to Helvering v. LeGierse, 312 U.S. 531,
539 (1941), [*7] in which the Court stated that "[h]istorically and commonly
insurance involves risk-shifting and risk-distributing." Case law has defined
"insurance" as "involve[ing] a contract, whereby, for an adequate consideration,
one party undertakes to indemnify another against loss arising from certain
specified contingencies or perils. . . It is contractual security against
possible anticipated loss." Epmeier v. United States, 199 F.2d 508, 509-10 (7th
Cir. 1952). In addition, the risk transferred must be risk of economic loss.
Allied Fidelity Corp. v. Commissioner, 572 F.2d 1190, 1193 (7th Cir.), cert.
denied, 439 U.S. 835 (1978).
[15] Risk shifting occurs when a party facing the possibility of an economic
loss transfers some or all of the financial consequences of the potential loss
to the insurer. See Rev. Rul. 92-93,
1992-2 C.B. 45 (while
parent corporation purchased a group-term life insurance policy from its wholly
owned insurance subsidiary, the arrangement was not held to be "self- insurance"
because the economic risk of loss was not that of the parent) modified [*8] on
other grounds, Rev. Rul. 2001-31, 2001-1
C.B. 1348. If the insured
has shifted its risk to the insurer, then a loss by the insured does not affect
the insured because the loss is offset by the insurance payment. See
Clougherty Packing Co. v. Commissioner, 811
F.2d 1297, 1300 (9th Cir. 1987).
[16] Risk distribution incorporates the statistical phenomenon known as the law
of large numbers. Distributing risk allows the insurer to reduce the possibility
that a single costly claim will exceed the amount taken in as a premium and set
aside for the payment of such a claim. Insuring many independent risks in return
for numerous premiums serves to distribute risk. By assuming numerous relatively
small, independent risks that occur randomly over time, the insurer smoothes out
losses to match more closely its receipt of premiums. See
Clougherty Packing Co., 811 F.2d at 1300.
[17] Based on the representations concerning Plans D, E, and F, we conclude
that, for federal income taxes, Plans D, E, and F are insurance contracts. The
plans are aleatory contracts under which Subsidiary is obligated to [*9]
indemnify the contract holders for economic loss arising from the mechanical
breakdown of a piece of equipment that is not covered by the manufacturer's
warranty. The plans are not prepaid service contracts because Subsidiary does
not perform any repair services. By accepting a large number of risks,
Subsidiary has distributed the risk of loss under the contracts so as to make
the average loss more predictable.
[18] Based on the representations concerning its business activities, we
conclude that Subsidiary will qualify for purposes of section 831 as an
insurance company other than a life insurance company so long as its primary and
predominant business activity is issuing the plans.
CONCLUSIONS
1. Plans D, E, and F are insurance contracts for federal income tax purposes.
2. Subsidiary will qualify as an insurance company for purposes of section 831
so long as issuing Plans D, E, and F is its primary and predominant business
activity.
CAVEATS
1. Except as expressly provided herein, no opinion is expressed or implied
concerning the tax consequences of any aspect of any transaction or item
discussed or referenced in this [*10] letter.
2. No ruling has been requested, and no opinion is expressed, concerning whether
Subsidiary's gross premiums written include the entire amount the purchasers of
Plans D, E, and F pay to the Taxpayer for the contracts.
3. No opinion is expressed concerning the purpose and motive of the transaction
or the application of sections 482 or 845 to the transaction.
[19] Section 6110(k)(3) of the Code provides that this letter may not be used or
cited as precedent. A copy of this letter must be attached to any income tax
return to which it is relevant.
[20] In accordance with the Power of Attorney on file with this office, a copy
of this letter is being sent to the first listed representative.
Sincerely,
THOMAS M. PRESTON
Senior Counsel, Branch 4
Office of Associate Chief Counsel
(Financial Institutions & Products)
PRIVATE RULING
200416006 ( PDF Version )
"This document may not be used or cited as precedent. Section 6110(j)(3) of the
Internal Revenue Code."
Section 832 -- Other Insurance Firm Income;
Section 831 -- Tax on Other Insurance Companies
DATE: January 6, 2004
REFER REPLY TO: [*1] Refer Reply To: CC:FIP:4 - PLR-143639-03
Release Date: 4/16/04
Legend
Individual A = * * *
Individual B = * * *
Network = * * *
State A = * * *
State B = * * *
Taxpayer = * * *
Administrator = * * *
Date m = * * *
Year 1 = * * *
Dear * * * :
[1] This is in reply to your letter of July 1, 2003, requesting rulings,
principally, that the contracts issued by Taxpayer qualify as insurance
contracts for federal income tax purposes and that Taxpayer is taxable under
section 831 of the Internal Revenue Code
as an insurance
company other than a life insurance company.
FACTS
[2] Individual A owns all the stock of the four of the seven auto dealerships
within the Network, and Individual B owns all of the stock of the remaining
dealerships. Beginning in Year 1, these dealerships sold vehicle service
agreements in which the selling dealer was the primary obligor to the purchaser
of the contract. Taxpayer, which was incorporated on Date m of Year 1, will be
responsible for the issuance and administration of the vehicle service
agreements issued to customers and will be the primary obligor on the
agreements. In addition, [*2] Taxpayer states that it will assume for
arms-length consideration, the outstanding risks on the dealer obligor vehicle
service agreements issued by the individual dealers within the Network. All of
the stock of Taxpayer is owed by Individual A.
[3] The vehicle service agreements issued by Taxpayer provide purchasers with
protection against economic loss for certain expenses related to the repair of
vehicles not covered by the manufacturer's warranty. In the event that the
manufacturer's warranty duplicates coverage under the contract, the contract
will not apply and the vehicle owner can only recover under the manufacturer's
factory warranty. The agreements under the vehicle service program typically
cover repairs made necessary by the failure of major systems or components; but
also include coverage of some incidental items caused by the failure of other
components such as tire repair and replacement, lockout, and trip interruption.
On the other hand, the agreements do not cover any preventative or routine
maintenance such as engine tune ups, or oil or other fluid changes unrelated to
a covered mechanical breakdown.
[4] The vehicle service agreements on new vehicles are renewable [*3] in that
a purchaser may purchase a vehicle service agreement for additional time and
mileage provided the purchaser makes a request within 30 days and 1,000 miles
prior to the expiration of the original agreement. On the other hand, the
purchaser may cancel a vehicle service agreement contract and receive a refund
of a portion of amounts paid as consideration for the agreement.
[5] Taxpayer's only business activity is the issuance and administration of the
vehicle service agreements offered by the Network whereby the selling dealer
acts as Taxpayer's agent. Under the vehicle service agreements Taxpayer will be
obligated to pay for the cost of labor and parts required for covered repairs,
even though, Taxpayer does not perform any repairs.
[6] While Taxpayer is not licensed as an insurance company under the laws of
State A, other State A law and administrative practices regarding the sale of
the contracts are applicable to Taxpayer. For example, State A law requires that
the obligor of the contract such as Taxpayer must secure its obligations under
the contract in an acceptable manner provided in the statute. Taxpayer will
purchase indemnity insurance from a licensed insurance company, [*4] which,
under the laws of State A, is one of the accepted methods available to Taxpayer
to secure its obligations. Under such an arrangement the contract obligor
remains liable to the customer, but its obligations under the contracts are
indemnified by the licensed insurer. Also, Taxpayer has entered into a program
administration agreement with Administrator, an unrelated State B limited
liability company whereby Administrator serves as program administrator for
Taxpayer's business with respect to the contracts and will conduct many of the
day-today record keeping and claims administration functions.
[7] Taxpayer represents as follows:
(1) As permitted by State A law, Taxpayer will be the administrator and the
named obligor on the vehicle agreements and is directly liable to the purchaser
under the terms of the vehicle service agreements,
(2) The predominant source of revenue collected by Taxpayer will be derived
from the issuance of vehicle service agreements with Taxpayer as obligor.
(3) Taxpayer does not perform any repair services covered pursuant to the
vehicle service agreements.
LAW AND ANALYSIS
[*5] [8] Section 831(a) of the Internal Revenue Code
provides that taxes,
as computed in section 11, are imposed for each taxable year on the taxable
income of each insurance company other than a life insurance company.
[9] Insurance companies subject to tax under section 832 of the Code are
required to determine gross income under section 832(b)(1). Section 832(b)(1)(A)
provides that one of the items taken into account is the combined gross amount
earned during the taxable year from investment income and from underwriting
income computed on the basis of the underwriting and investment exhibit of the
annual statement approved by the National Association of Insurance
Commissioners. Section 832(b)(3) defines "underwriting income" as premiums
earned on insurance contracts during the taxable year less losses incurred and
expenses incurred. Section 832(b)(4) provides that "premiums earned on insurance
contracts during the taxable year" is the amount generally computed as follows:
(1) from the amount of gross premiums written on insurance contracts during the
taxable year, deduct return premiums and premiums paid for reinsurance; and (2)
to the amount determined [*6] in (1) add 80% of the unearned premiums on
outstanding business at the end of the preceding taxable year and deduct 80% of
the unearned premiums on outstanding business at the end of the taxable year.
[10] Section 1.831-3(a) of the Income Tax Regulations
provides that, for
purposes of sections 831 and 832 of the Code, the term "insurance companies"
means only those companies that qualify as insurance companies under the
definition in former section 1.801-1(b) (now section 1.801-3(a)(1)) of the
regulations.
[11] Section 1.801-3(a)(1) of the regulations provides that the term "insurance
company" means a company whose primary and predominant business activity during
the taxable year is the issuing of insurance or annuity contracts or the
reinsuring of risks underwritten by insurance companies. Section 1.803-3(a)(1)
further provides that though the company's name, charter powers, and subjection
to state insurance laws are significant in determining the business that a
company is authorized to carry on, it is the character of the business actually
done in the taxable year that determines whether the company is taxable as an
insurance company under [*7] the Code. See also Bowers v. Lawyers Mortgage Co.,
285 U.S. 182, 188 (1932)
(to the same effect as
the regulation); Rev. Rul. 83-172, 1983-2 C.B. 107
(holding that the
taxpayer was an "insurance company," as defined in section 1.801- 3(a)(1),
notwithstanding that the taxpayer was not recognized as an insurance company for
state law purposes).
[12] Neither the Code nor the regulations define the terms "insurance" or
"insurance contract." The accepted definition of insurance for federal income
tax purposes relates back to Helvering v. LeGierse, 312 U.S. 531, 539 (1941),
in which the Supreme
Court stated that "[historically and commonly insurance involves risk-shifting
and risk distributing. Case law has defined "insurance" as "involve[ing] a
contract, whereby for valuable consideration, one party undertakes to indemnify
another against a loss arising from certain specified contingencies or perils. .
. [I]t is contractual security against possible anticipated loss." See Epmeier
v. United States, 199 F.2d 508, 509-510 (7th Cir. 1952).
In addition, the risk
transferred [*8] must be risk of economic loss. Allied Fidelity Corp. v.
Commissioner, 572 F.2d 1190, 1193
(7th Cir.), cert.
denied, 439 U.S. 835 (1978).
[13] Risk shifting occurs when a person facing the possibility of an economic
loss transfers some or all of the financial consequences of the potential loss
to the insurer. See Rev. Rul. 92- 93, 1992-2 C.B. 45, 45,
as modified by Rev.
Rul. 2001-31, 2001-1 C.B. 1348
(while parent
corporation purchased a group-term life insurance policy from its wholly owned
insurance subsidiary, this did not cause the arrangement to be "self-insurance"
because the economic risk of loss was not that of parent). If the insured has
shifted its risk to the insurer, then a loss by the insured does not affect the
insured because the loss is offset by the insurance payment. See Clougherty
Packing Co. v. Commissioner, 811 F.2d 1297, 1300 (9th Cir. 1987).
[14] Risk distribution incorporates the statistical phenomenon known as the law
of large numbers. Distributing risk allows the insurer to reduce the
possibility [*9] that a single costly claim will exceed the amount taken in as
a premium and set aside for the payment of such a claim. Insuring many
independent risks in return for numerous premiums serves to distribute risk. By
assuming numerous relatively small, independent risks that occur randomly over
time, the insurer smoothes out losses to match more closely its receipt of
premiums. See Cloughtery Packing Co., 811 F.2d at 1300.
[15] Based on the information submitted, we conclude that, for federal income
tax purposes, the vehicle service agreements are insurance contracts, not
prepaid service contracts. Unlike prepaid service contracts, the contracts are
aleatory contracts under which Taxpayer, for a fixed price, is obligated to
indemnify the purchaser of the contract for economic loss not covered by
warranties provided by a manufacturer, arising from the mechanical breakdown of,
and repair expense to, a purchased motor vehicle. Thus, the contracts are not
prepaid service contracts because Taxpayer's liability is limited to
indemnifying the vehicle service agreement contractholder for losses in the
event a mechanical breakdown occurs. Taxpayer does not provide any [*10] repair
services itself and does not provide reimbursement for any obligations that are
properly the obligations of the manufacturer. Further, by accepting a large
number of risks, Taxpayer has distributed the risk of loss under the vehicle
service contracts so as to make the average loss more predictable.
[16] Based on Taxpayer's representations concerning its business activities, we
find Taxpayer's "primary and predominant activity," is issuing vehicle service
agreements that are insurance contracts for federal income tax purposes. Thus,
Taxpayer qualifies as an "insurance company" for purposes of section 831 of the
Code.
CONCLUSIONS
-
The
vehicle service agreements issued by Taxpayer, as described above, are
considered insurance contracts for federal tax purposes.
-
Taxpayer
is taxable under section 831(a) as an insurance company other than a life
insurance company.
-
Taxpayer
is entitled under section 832(b)(4) to deduct premiums paid to a licensed
insurance company for a contract protecting Taxpayer against losses incurred
with respect to its obligations to purchasers under the Taxpayer's
vehicle [*11] service agreements.
CAVEATS
-
Except as
expressly provided herein, no opinion is expressed or implied concerning the
tax consequences of any aspect or item discussed or referenced in this
letter.
-
No ruling
has been requested, and no opinion is expressed, concerning whether
Taxpayer's gross premiums include the entire amount the purchasers of the
vehicle service agreements pay to the dealers within the Network for
their contracts.
-
No opinion
is expressed as to the federal tax treatment of the proposed arrangements
whereby Taxpayer will assume the outstanding risks from the individual
dealers in the Network that those dealers assumed under their respective
dealer obligor contracts.
[17] The rulings contained in this letter are based upon information and
representations submitted by Taxpayer. While this office has not verified
any of the material submitted in support of the request for rulings, it is
subject to verification on examination.
[18] The ruling is directed only to the taxpayer requesting it. Section
6110(k) of the Code provides that it may not be used or cited [*12] as
precedent. A copy of this letter must be attached to any income tax return
to which it is relevant.
[19] Pursuant to the power of attorney on file with this office, a copy of
this letter is being sent to your authorized representative.
Sincerely,
/S/
THOMAS M. PRESTON
Senior Counsel, Branch 4
Office of Associate Chief Counsel
(Financial Institutions & Products)
PRIVATE RULING
200138010 ( PDF Version )
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