California Revenue and Taxation Code

§ 24465

RTC § 24465 Effective Oct 1, 2025Div. 2 · Part 11 · Ch. 8

Statute text

(a)(1) If, in connection with any exchange described in Section 332, 351, 354, 356, or 361 of the Internal Revenue Code, a taxpayer transfers property to an insurer, the insurer shall not, for purposes of determining the extent to which gain shall be recognized on that transfer, be considered to be a corporation for purposes of this part.

(2)Paragraph (1) shall not apply to any of the following types of transactions, unless that transaction has the effect (directly or indirectly) of transferring appreciated property from a taxpayer subject to tax under this part (or a member of the taxpayer’s combined reporting group) to an insurer:

(A)An exchange or transfer pursuant to Section 368(a)(2)(D) or Section 368(a)(2)(E) of the Internal Revenue Code.

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Legislative history

Amended by Stats. 2025, Ch. 231, Sec. 107. (SB 711) Effective October 1, 2025.