fresh-start approach

  • Transitional rule in the 1984 Tax Reform Act reserve formula that precludes the recapture of previously deducted reserve increases by life insurance companies, regardless of their amount. A similar fresh-start rule was contained in the Tax Reform Act of 1986 for the discounted loss reserves of property and casualty insurance companies.

    Internal Revenue Service 1

1Internal Revenue Service, Internal Revenue Manual 4.42.6 Glossary, http://­­irm/­part4/­irm_04-042-006.html (last accessed Dec. 22, 2009).