Prudential Insurance Co. of America v. Commissioner of Revenue

We consider whether it is lawful for the Commonwealth to calculate retaliatory taxes on insurance premiums of a foreign insurer separately for life insurance premiums and for premiums on all other lines of insurance. On the appeal of The Prudential Insurance Company of America (Prudential) from a ruling of the Commissioner of Revenue (commissioner), the Appellate Tax Board (board) concluded that the separate treatment of Prudential’s life insurance premiums and health and accident premiums for retaliatory tax purposes was required by statute and did not violate the equal protection provisions…