Bringing Certainty To An Uncertain Tax Position

Law360, New York (August 21, 2012, 1:13 PM EDT) -- On July 30, 2012, the U.S. Internal Revenue Service Large Business & International (LB&I) Division issued guidelines intended to reduce the controversy associated with partial worthlessness deductions claimed by insurance companies.

In brief, the guidelines, which were released as an industry director directive, instruct IRS examiners not to challenge partial worthlessness deductions claimed by an insurance company under § 166(a)(2)* if:

They are limited to the credit-related portion of the impairment charge-off (not the full fair market value); and They comport with the National Association of...
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