Gross Receipts - Exempt Insurance Companies (Section 501(c)(15))
The IRS has provided guidance on the meaning of gross receipts for purposes of determining whether small insurance companies qualify as tax-exempt under section 501(c)(15) of the Internal Revenue Code. Section 501(c)(15) uses a test based on an entity's gross receipts during the taxable year to determine if it is exempt from federal income taxation for the year. In general, gross receipts includes premium income, gross investment income, and other income included under the Code's insurance tax provisions. Notice 2006-42 concludes that tax-free interest and amounts treated as gain (but not the entire amount realized) from the sale or exchange of capital assets are included in calculating gross receipts.