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PUBLIC LAW 429-MAR. 13, 1956
[70 STAT.
"SEC. 813. ADJUSTMENT FOR CERTAIN RESERVES. "In the case of a life insurance company writ in (j contracts other than life insurance, annuity, and noncancellable health and accident insurance contracts (including life insurance or annuity contracts combined with noncancellable health and accident insurance), the term 'adjustment for certain reserves' means, for purposes of this subpart, an amount equal to 314 percent of the unearned premiums and unpaid losses on such other contracts which are not included in life insurance reserves (as defined in section 801(b)). For purposes of this section, such unearned preniiums shall not be considered to be less than 25 percent of the net premiums written during the taxable year on such other contracts. "Subpart C—Miscellaneous Provisions "Sec. S16. Foreifin life insuraiu-e coinpaiiies. "Sec. 817. Denial of double deductions. "Sec. <S18. Certain new insurance companies.
"SEC. 816. FOREIGN LIFE INSURANCE COMPANIES. " (a) CARRYING ON IlNrrKO STATES INSURANCE I^USIXESS.—A foreign life insurance company carrying on a life insurance business within the United States, if with respect to its Ignited States business it would qiuilify as a life insurance company under section 801, shall be taxable in the same manner as a domestic life insurance company; except that the determinations necessary for purposes of this subtitle shall be made on the basis of the income, disbursements, assets, and liabilities reported in the annual statement for the taxable year of the United States business of such company on the form approved for life insurance companies by the National Association of Insurance Commissioners. " (b) Xo UNITED STATES INSURANCE BUSINESS.—Foreign life insurance companies not carrying on an insurance business within the United States shall not be taxable under this part but shall be taxable as other foreign corporations. "SEC. 817. DENIAL OF DOUBLE DEDUCTIONS. "Nothing in this part shall permit the same item to be deducted more than once. "SEC. 818. CERTAIN NEW INSURANCE COMPANIES. " (a) GENERAL RULE.—If the taxable year begins not more than 0 years after the first day on which the taxpayer was authorized to do business as an insurance company, then— "(1) for purposes of subpart A, the life insurance taxable income shall not exceed (A) the amount of the net gain from operations after dividends to policyholders, reduced by (B)(i) the net investment income allocable to non-life insurance reserves and (ii) the special reduction for dividends received provided by subsection (c); or "(2) for purposes of subpart B, the life insurance company taxable income shall not exceed (A) the amount of the net gain from operations after dividends to policyholders, reduced by (B) the special reduction for dividends received provided by subsection (c). For purposes of this subsection, the net gain from operations after dividends to policyholders shall be computed in the manner required for purposes of the annual statement approved by the National Convention of Insurance (Commissioners, except that no reduction shall be made for any Federal income tax.
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