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IRS on Section 953(d) Election

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IRS on Section 953(d) Election

Postby Riser Adkisson LLP » Sun Dec 14, 2008 8:26 am

SOURCE: Foreign Insurance Excise Tax - Audit Technique Guide, April 2008, as found at http://www.irs.gov/businesses/small/art ... 63,00.html NOTE: This document is not an official pronouncement of the law or the position of the Service and can not be used, cited, or relied upon as such. This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date.

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Section 953(d) Election Information

When a taxpayer makes an election under IRC § 953(c) or (d), they are required to file a request for election with the Internal Revenue Service. The Service reviews the application and approves or denies the request. The application is then filed and retained by the Internal Revenue Service. Agents may contact the Foreign Insurance EIS for verification that an election was made if the taxpayer is unable to provide substantiation of the election. Given that the taxpayer has relied upon a section 953(d) election in filing or not filing an excise tax return. It is the taxpayer’s responsibility to maintain substantiation of the election relied upon.
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Riser Adkisson LLP
The Captive Insurance Lawfirm - http://www.risad.com
The Captive Insurance Lawfirm - http://www.risad.com
 
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