501(c)(15) Overcapitalization ("Stuffing") Transactions
This notice states that an organization qualifies as a section 501(c)(15) organization only if its primary and predominant business activity during the taxable year is issuing insurance or annuity contracts or reinsuring risks underwritten by insurance companies. In addition, legislation enacted on April 10, 2004 substantially modifies section 501(c)(15) to address the stuffing concerns.
This notice provides guidance on how to calculate gross receipts for purposes of determining whether an insurance company is tax-exempt under section 501(c)(15).
This bill summary provides the portions of this Act affecting 501(c)(15) organizations.