Tax Treatment of Workers' Compensation Funds (Pooled Self-Insurance Funds) : Scheduled for a Hearing Before the Subcommittee On Select Revenue Measures of the Committee On Ways And Means On April 7, 1987 Jcs-8-87

Cover Tax Treatment of Workers' Compensation Funds (Pooled Self-Insurance Funds) : Scheduled for a Hearing Before the Subcommittee On Select Revenue Measures of the Committee On Ways And Means On April 7, 1987 Jcs-8-87
Tax Treatment of Workers' Compensation Funds (Pooled Self-Insurance Funds) : Scheduled for a Hearing Before the Subcommittee On Select Revenue Measures of the Committee On Ways And Means On April 7, 1987 Jcs-8-87
United States. Congress. Joint Committee On Taxation
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Policyholder dividends are generally considered price rebates and are not taxable distributions (unless the insurance pre- miums were deducted by the policyholder). Dividends paid to share- holders in their capacity as shareholders, on the other hand, consti- tute ordinary income to the recipient shareholders to the extent of the distributing corporation's earnings and profits.
Deductibility of policyholder dividends Under present law, a deduction is permitted for dividends and similar distribu
...tions paid or declared to policyholders in their ca- pacity as such (sec. 832 (c)(ll)) in determining the taxable income of a property and casualty insurance company. For purposes of this deduction, the statute provides that the term "paid or declared" is construed according to the method of accounting regularly em- ployed in keeping the books of the insurance company. Treasury regulations provide that deductible dividends to policyholders in- clude amounts returned to policyholders if the amount is not fixed in the insurance contract but depends on the experience of the company or the discretion of the management (Treas.

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