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501(c)(15) Producer Owned Reinsurance Companies (PORC)

 

Notice 2002-70

This notice explains how section 501(c)(15) organizations are used in these transactions.

Revenue Ruling 2002-89

This revenue ruling provides guidance on whether arrangements between a parent and its subsidiary insurance company qualified as an insurance arrangement and whether premiums paid were deductible under Internal Revenue Code section 162.

Revenue Ruling 2002-90

This revenue ruling addresses whether amounts paid for professional liability coverage by domestic operating subsidiaries to an insurance subsidiary of a common parent are deductible as insurance premiums under Code section 162.

Revenue Ruling 2002-91

This revenue ruling discusses whether a "group captive" formed by a small group of unrelated businesses in a highly concentrated industry to provide insurance coverage for the businesses is an insurance company within the meaning of Code section 831.

Notice 2003-35

This notice reiterates that an organization qualifies as a section 501(c)(15) organization only if its primary and predominant business activity during the taxable year is issuing insurance or annuity contracts or reinsuring risks underwritten by insurance companies.