SECTION 1. PURPOSE
Internal Revenue Bulletin 2007-40 · 2026-10-03 edition · updated 2026-10-04 · United States
This revenue procedure provides a safe harbor under which an insurance company subject to tax under subchapter L of the Internal Revenue Code is not required to take into account any portion of the increase for the taxable year in policy cash values of life insurance contracts described in § 264(f)(4)(A) (I-COLI Contracts) for purposes of applying the insurance company
proration rules in §§ 807(a)(2), 807(b)(1), 805(a)(4), 812, or 832(b)(5).
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