Income Tax Consequences of Demutualization

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2008-08-29
Authors
Harl, Neil
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Abstract

The shift from member-owned, mutual insurance companies, to policyholder-owned firms, often publicly-traded, has produced a dramatic reordering of the insurance landscape in recent years.1 The move, facilitated by changes in state insurance laws, has involved an exchange of shares (or money) for the members’ ownership rights in the company which included voting and distribution rights as well as contractual insurance rights. One reason often given for the move has been to position the company to conduct an initial public offering of securities.

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