Rulings on Corporate Reorganizations and Corporate Transactions

  • PLR 201648004 (Aug. 26, 2016) (application of section 382(l)(5) to proposed transaction involving participating funds)
     
  • PLR 201511015 (Nov. 14, 2014) (application of section 351 and reinsurance provisions to intercompany reinsurance transaction)
     
  • PLR 201348006 (Sept. 3, 2013) (transfer of structured settlement business to Newco in section 351 transaction)
     
  • PLR 200804010 (Jan. 25, 2008) (Various rulings on merger of two mutual life insurance companies);
     
  • PLR 9910013 (Dec. 4, 1998) (First ruling granting extension of time under Treas. Reg. § 301.9100 to make election to apply 1995 consolidated return intercompany transaction rules); and
     
  • PLR 9745013 (Aug. 7, 1997) (First ruling to address the conversion of a mutual insurance company to a stock insurance company under a mutual holding company structure);
     
  • PLR 9313020 (Dec. 30, 1992) supplemented by PLR 9314016 (Jan. 6, 1993) (First rulings holding that the transfer of the business of a mutual insurer in rehabilitation to its subsidiary qualified as a tax-free “G” reorganization); with regard to the same rehabilitation, received PLR 9339024 (July 7, 1993) (First ruling regarding the impact of a rehabilitation on insurance annuity contracts held in connection with qualified retirement plans); PLR 9544026 (Aug. 4, 1995) (Similar tax-free “G” reorganization rulings on the rehabilitation of a mutual life insurer);
     
  • PLR 8851016 (Sept. 22, 1988) (First ruling issued on tax consequences of a mirror subsidiary corporate acquisition); and
     
  • PLR 8812047 (Dec. 23, 1987), supplemented by PLR 8825013 (Mar. 15, 1988) and PLR 8818047 (Feb. 10, 1988) (First ruling on life-nonlife consolidated return consequences of creation of insurance holding company).
     
  • PLR 8617088 (Jan. 29, 1986) (First ruling on tax-free reorganization or liquidation of insurance company prior to selling the insurance charter and licenses).
UpdatedL. Wright