Article
IRS Rules That Quota Share Reinsurance Arrangements Are "Insurance" And Continues To Apply Prior Principles
On December 11, 2009, in Private Letter Rulings 200950016 and 200950017, the IRS ruled that quota share reinsurance arrangements qualified as "insurance" for federal income tax purposes based upon the fact that both risk shifting and risk distribution were present in the arrangements.
Sutherland Asbill & Brennan LLP




