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Tax Resources
831(b) Tax Election
First $2.3 MM of Annual Premium Ceded is Tax Free
Qualifying Elements
Risk Shifting
Risk Distribution
Safe Harbor Rulings
Rev.Rul. 2002-89
50% Unaffiliated Risk
Rev. Rul. 2009-26
Recognized reinsurance Under 831(b) Tax Code
Private Letter Rulings
Recognized Pro-Rata Sharing
PLR 200950016
PLR 200950017
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