Report to Congress on the Taxation of Income Earned by Members of Insurance or Reinsurance Syndicates

摘要

The report mandated by Section 10244 of the Omnibus Budget Reconciliation Act of 1987 is on the taxation of income earned by members of insurance or reinsurance syndicates. The study was made because of Congressional concern that a 1980 closing agreement between the Internal Revenue Service and underwriters at Lloyd's of London may require revision to account for changes in the U.S. taxation of insurance income since 1980. Congress was also concerned about the possibility that the closing agreement might create an inappropriate disparity between the taxation of underwriters at Lloyd's of London and U.S. underwriters who are members of Lloyd's-type syndicates formed in the United States. As a result of the study, it was concluded that the 1980 closing agreement with the underwriters at Lloyd's of London should be revised.