IRS Rules that Retroactive Reinsurance is not Reinsurance for Tax Purposes

IRS Rules that Retroactive Reinsurance is not Reinsurance for Tax Purposes, T3: Taxing Times Tidbits, 30 Taxing Times, Vol. 3, Issue 3 (September 2007) (Co-authored with Susan J. Hotine and Peter H. Winslow). Click here for Full Text (PDF)