Opinion Number

Dear Mr. Karns,

You have requested our interpretation of the portion of LSA-R.S.22:1382 (A)(3)(c) underlined below. This interpretation impacts the term of years that a certificate of contribution can be used to offset a member's premium (license) tax liability. Specifically, you inquired whether the time period of the offset is limited to ten years.

LSA-R.S. 22:1382 (A)(3)(c) provides as follows:

A certificate of contribution issued to a member company shall be offset against its premium tax liability in an amount not to exceed ten percent of the assessment for the year of assessment and not to…