996 Ante, p. 994.
Ante. p. 989.
PUBLIC LAW 8 7 - 8 3 4 - O C T. 16, 1962
" (A) the amount required to be subtracted from the protection agaJust loss account under section 824(d)(1)(C) for the offset year, plus " (B) the mutual insurance company taxable income for the offset year. For purposes of paragraphs (1) and (2)(B), the mutual insurance company taxable income for the offset year shall be determined without regard to any unused loss carryback or carryover from the loss year or any taxable year thereafter. " (g) LIMITATIONS.—For purposes of this part, an unused loss shall not be carried— "(1) to or from any taxable year beginning before January 1, 1963, "(2) to or from any taxable year for which the insurance company is not subject to the tax imposed by section 821(a), nor "(3) to'^any taxable year if, between the loss year and such taxable year, there is an intervening taxable year for which the insurance company was not subject to the tax imposed by section 821(a). "SEC. 826. ELECTION BY RECIPROCAL. " (a) IN GENERAL.—Except as otherwise provided in this section, any mutual insurance company which is an interinsurer or reciprocal underwriter (hereinafter in this section referred to as a 'reciprocal') subject to the taxes imposed by section 821(a) may, under regulations )rescribed by the Secretary or his delegate, elect to be subject to the imitation provided in subsection (b). Such election shall be effective for the taxable year for which made and for all succeeding taxable years, and shall not be revoked except with the consent of the Secretary or his delegate. " (b) LiMiTAiTON.—The deduction for amounts paid or incurred in the taxable year to the attorney-in-fact by a reciprocal making the election provided in subsection (a) shall be limited to, but in no case increased by, the deductions of the attorney-in-fact allocable, in accordance with regulations prescribed by the Secretary or his delegate, to the income received by the attorney-in-fact from the reciprocal. "(c) ExcEFfiON.—An election may not be made by a reciprocal under subsection ^a) unless the attorney-in-fact of such reciprocal— "(1) is subject to the taxes imposed by section 11(b) and (c); "(2) consents in such manner as the Secretary or his delegate shall prescribe by regulations to make available such information as may be required during the period in which the election provided in subsection (a) is in effect, under regulations prescribed by the Secretary or his delegate; "(3) reports the income received from the reciprocal and the deductions allocable thereto under the same method of accounting under which the reciprocal reports deductions for amounts paid to the attorney-in-fact; and " (4) files its return on the calendar year basis. " (d) SPECIAL RULE. — I n applying section 8 2 4 (d)(1)(D), any amount which was added to the protection against loss account by reason of an election under this section shall be treated as having been added by reason of section 824(a)(1)(A). "(e) CREDIT.—Any reciprocal electing to be subject to the limitation provided in subsection (b) shall be credited with so much of the tax paid by the attorney-in-fact as is attributable, under regulations pi-escribed by the Secretary or his delegate, to the income received by the attorney-in-fact from the reciprocal in such taxable year.
26 USC II; Ante, p. 114.
i4nte, p.994. Ante, p. 993.