Page:United States Statutes at Large Volume 100 Part 3.djvu/601

 PUBLIC LAW 99-514—OCT. 22, 1986

100 STAT. 2409

(A) is from a taxable year beginning before January 1, 1987, and (B) could have been carried under such section to a taxable year beginning after December 31, 1986, but for the repeal made by subsection (a)(1), shall be included in the net operating loss deduction under section 832(c)(10) of such Code without regard to the limitations of section 844(b) of such Code. (e) EFFECTIVE DATE.—The amendments made by this section (and the provisions of subsection (d)) shall apply to taxable years beginning after December 31, 1986. SEC. 1025. STUDY OF TREATMENT OF PROPERTY AND CASUALTY INSURANCE COMPANIES.

The Secretary of the Treasury or his delegate shall conduct a study of^ (1) the treatment of policyholder dividends by mutual property and casualty insurance companies, (2) the treatment of property and casualty insurance companies under the minimum tax, and (3) the operation and effect of, and revenue raised by, the amendments made by this subtitle. Not later than January 1, 1989, such Secretary shall submit to the Committee on Ways and Means of the House of Representatives, the Committee on Finance of the Senate, and the Joint Committee on Taxation, the results of such study, together with such recommendations as he determines to be appropriate. The Secretary of the Treasury shall have authority to require the furnishing of such information as may be necessary to carry out the purposes of this section.

Subtitle D—Miscellaneous Provisions SEC. 1031. PHYSICIANS' AND SURGEONS' MUTUAL PROTECTION AND INTERINDEMNITY ARRANGEMENTS OR ASSOCIATIONS. (a) CERTAIN PHYSICIANS' AND SURGEONS' MUTUAL PROTECTION AND INTERINDEMNITY ARRANGEMENTS OR ASSOCIATIONS.— (1) TREATMENT OF ARRANGEMENTS OR ASSOCIATIONS.— (A) CAPITAL CONTRIBUTIONS.—There shall not be included

in the gross income of any eligible physicians' and surgeons' mutual protection and interindemnity arrangement or association any initial payment made during any taxable year to such arrangement or association by a member joining such arrangement or association which— (i) does not release such member from obligations to pay current or future dues, assessments, or premiums; and (ii) is a condition precedent to receiving benefits of membership. Such initial payment shall be included in the gross income of such arrangement or association for such taxable year if it is reasonable to expect that such payment will be deductible pursuant to paragraph (2) by any member of such arrangement or association. (B) RETURN OF CONTRIBUTIONS.—

�