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Provisional Indemnification Receivables Includable in Foreign Insurer’s Subpart F Income, IRS Says

April 19, 2010 in Daily Tax Report · Leave a Comment 

The Internal Revenue Service national office in Technical Advice Memorandum 201015030, released April 16, said provisional indemnification receivables (PIRs) for incurred but not reported loss reserves are includable in the calculation of Subpart F insurance income of a foreign insurer and its earnings and…

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