Description: An explanation of the reasons why the IRS should rule on the application of section 351 to the transfer of assets and reserves in an indemnity coinsurance transaction where the ceding company transfers more assets to the assuming company than it would in an arms-length transaction and, therefore, the ceding company actually receives or is deemed to receive stock in the exchange for the transferred assets including the value of insurance in force. We also will summarize other interesting rulings in the PLR.

Description: One major feature of the OECD's two-pillar regime is that MNEs would base the calculation of taxes due on book-based financial statements. The article provides a summary of how these rules operate along with suggested actions insurers can take today to prepare for timely compliance.