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    Created by Michael Wessels
    1. U.S. Code
    2. Title 26
    3. Subtitle A
    4. CHAPTER 1
    5. Subchapter L
    6. PART I
    7. Subpart D

    § 811 Accounting provisions

    (a) Method of accounting

    All computations entering into the determination of the taxes imposed by this part shall be made—

    (1) under an accrual method of accounting, or

    (2) to the extent permitted under regulations prescribed by the Secretary, under a combination of an accrual method of accounting with any other method permitted by this chapter (other than the cash receipts and disbursements method).

    (b) Amortization of premium and accrual of discount

    (1) In general

    The appropriate items of income, deductions, and adjustments under this part shall be adjusted to reflect the appropriate amortization of premium and the appropriate accrual of discount attributable to the taxable year on bonds, notes, debentures, or other evidences of indebtedness held by a life insurance company. Such amortization and accrual shall be determined—

    (A) in accordance with the method regularly employed by such company, if such method is reasonable, and

    (B) in all other cases, in accordance with regulations prescribed by the Secretary.

    (2) Special rules

    (A) Amortization of bond premium

    In the case of any bond (as defined in ), the amount of bond premium, and the amortizable bond premium for the taxable year, shall be determined under as if the election set forth in had been made.

    (B) Convertible evidence of indebtedness

    In no case shall the amount of premium on a convertible evidence of indebtedness include any amount attributable to the conversion features of the evidence of indebtedness.

    (3) Exception

    No accrual of discount shall be required under paragraph (1) on any bond (as defined in section 171(d)), except in the case of discount which is—

    (A) interest to which section 103 applies, or

    (B) original issue discount (as defined in section 1273).

    (c) No double counting

    Nothing in this part shall permit—

    (1) a reserve to be established for any item unless the gross amount of premiums and other consideration attributable to such item are required to be included in life insurance gross income,

    (2) the same item to be counted more than once for reserve purposes, or

    (3) any item to be deducted (either directly or as an increase in reserves) more than once.

    (d) Method of computing reserves on contract where interest is guaranteed beyond end of taxable year

    For purposes of this part (other than section 816), amounts in the nature of interest to be paid or credited under any contract for any period which is computed at a rate which—

    (1) exceeds the interest rate in effect under for the contract for such period, and

    (2) is guaranteed beyond the end of the taxable year on which the reserves are being computed,

    (e) Short taxable years

    If any return of a corporation made under this part is for a period of less than the entire calendar year (referred to in this subsection as “short period”), then section 443 shall not apply in respect to such period, but life insurance company taxable income shall be determined, under regulations prescribed by the Secretary, on an annual basis by a ratable daily projection of the appropriate figures for the short period.