What Is a 953(d) Election and Why Did We Do It?
The Internal Revenue Code 953(d) authorizes non-US-based life insurance companies to elect to be treated and taxed the same as US-based life insurance companies. Castle Re made such an election and it files a 1120L annual corporate tax return with the IRS properly reporting all of its earnings. So, you might ask why Castle Re would elect to be subject to US corporate income taxation?
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