Rev. Proc. 83-57

SECTION 1. BACKGROUND

Rev. Proc. 83-22, 1983-1 C.B. 680, sets forth areas in which advance rulings or determination letters will not be issued by the Internal Revenue Service. Section 5 of Rev. Proc. 83-22 is entitled, Areas Under Extensive Study in Which Rulings or Determination Letters Will Not Be Issued Until the Service Resolves the Issue Through Publication of a Revenue Ruling, Revenue Procedure, Regulations or Otherwise.

SEC. 2. PROCEDURE

Rev. Proc. 83-22 is hereby amended by adding to section 5 the following new subsections;

Section 334(b)(2) (pre-TEFRA) Liquidation of Subsidiary.- Whether an acquiring corporation may treat the life insurance reserves received in the liquidation as unsecured liabilities assumed.

Section 336 (pre-TEFRA)-Distribution of Property in Liquidation. Whether the liquidation of a life insurance subsidiary is a termination pursuant to section 815(d)(2).

Section 338 (pre-TEFRA section 334(b)(2))-Certain Stock Purchases Treated as Asset Acquisitions.

The tax consequences, under subchapter L, from the stock purchase and the deemed purchase of the assets of a life insurance subsidiary. Section 802(b)(3)-Life Insurance Company Taxable Income Defined.

Whether the liquidation of a life insurance subsidiary pursuant to either section 334(b)(2) (pre-TEFRA) or section 338 (added by TEFRA) is a termination under section 315(d)(2) causing a distribution from the subsidiary's policyholders surplus account.

Section 809(d)(11)-Other Deductions.

Whether a portion of the purchase price of the stock of the life insurance subsidiary is properly allocable to insurance in force.

Section 801(b)-Life Insurance Reserves Defined.

Whether the life insurance reserves acquired in the liquidation of a life insurance subsidiary qualify as unsecured liabilities assumed by the acquiring corporation for purposes of section 334(b)(2) (pre-TEFRA) and section 338 (added by TEFRA).

Section 815(d)(2)-Termination as Life Insurance Company.

Whether the liquidation of a life insurance subsidiary pursuant to section 334(b)(2) (pre-TEFRA) or section 338 (added by TEFRA) is a termination requiring the application of section 802(b)(3).

Section 817-Rules Relating to Certain Gains and Losses.

Whether the purchase of the stock of a life insurance subsidiary and its subsequent liquidation under section 334(b)(2) (pre-TEFRA) or section 338 (added by TEFRA) is in fact, a purchase of the subsidiary's insurance contracts.

Section 818(b)(3)-Amortization of Premium and Accrual of Discount-Exception.

Whether the difference between the face value of bonds held by a life insurance subsidiary liquidating under section 334(b)(2) (pre-TEFRA) or section 338 (added by TEFRA) and the amount allocable to such bonds pursuant to the liquidation is market discount and need not be accrued.

SEC. 3. EFFECTIVE DATE

This revenue procedure will apply to all ruling requests currently on hand in the National Office on August 1, 1983, the date of publication of this revenue procedure in the Internal Revenue Bulletin, as well as to requests received thereafter.

SEC. 4. EFFECT ON OTHER REVENUE PROCEDURES

Rev. Proc. 83-22 is amplified