To qualify as a life insurer for federal income tax purposes, what percent of the mean of the company’s reserves must constitute life insurance…

For an insurance company to be classified as a "life insurance company" for U.S. federal income tax purposes, it must satisfy the reserve test defined in the Internal Revenue Code. This test requires that the sum of its life insurance reserves and its unearned premiums and unpaid losses on noncancellable life, accident, or health policies must comprise more than 50 percent of its total reserves. This statutory threshold ensures that the company's predominant business is life insurance, thereby justifying its taxation under the specific rules applicable to life insurers.

A. 25: This percentage is incorrect and falls significantly short of the statutory requirement for qualifying as a life insurer.

B. 50: The law specifies "more than 50 percent." A company with reserves at exactly 50 percent would fail to meet the qualification test.

C. less than 50: This is the inverse of the actual requirement; a company with reserves below this threshold would not qualify as a life insurer.

1. Internal Revenue Code, 26 U.S.C. § 816(a). This is the primary legal source defining a life insurance company for tax purposes. Section 816(a) explicitly states the "more than 50 percent" rule for the reserve test.

2. Pike, A. D. (2023). Federal Income Taxation of Life Insurance Companies. American Bar Association. Chapter 2, Section II.A, "The 'More Than 50 Percent' Reserve Test." This treatise details the application of IRC § 816(a).

3. KPMG. (2023). Taxation of Insurance Companies - United States. Section 3.2, "Definition of a life insurance company." This publication, often used in advanced accounting and tax courses, explains that "a company is a life insurance company for US federal income tax purposes if its life insurance reserves... comprise more than 50% of its total reserves."

4. PricewaterhouseCoopers (PwC). (2022). U.S. Taxation of Insurance Companies. Chapter 2, "Life Insurance Company Taxation," pp. 10-12. This guide, used as a reference in professional and academic settings, confirms the "more than 50 percent of total reserves" test under IRC Sec. 816.