Description of the Technical Corrections Act of 1988 (H.R. 4333 And S. 2238) Jcs-10-88

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shareholders (or persons related to such shareholders).
Definition of related person insurance income As stated above, the Act defines related person insurance income as a type of "insurance income." The Code provides special rules for computing tax haven insurance income that is subject to cur- rent taxation under subpart F. Section 953(b) states that for these purposes all items of income, expenses, losses, and deductions shall be properly allocated or apportioned under regulations prescribed
... by the Secretary. Section 953(b) also eliminates or limits the appli- cability of certain provisions of subchapter L of the Code ("Insur- ance Companies") for these purposes. Congress intended that these special rules for computing tax haven insurance income apply in computing related person insurance income.
Information returns Under the Code, U.S. persons who own or acquire 5 percent or more of the value of the stock of a foreign corporation, others who become U.S. persons while owning that percentage of the stock of a foreign corporation, and U.S.


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