Mutual Holding Co. v. Limbach

By this appeal we are asked to determine whether a wholly owned noninsurance subsidiary of a domestic insurance company is exempt under R.C. 5725.25 from paying franchise tax if the parent pays the franchise tax on domestic insurance companies imposed by R.C. 5725.18. We hold that a noninsurance corporation that is a subsidiary of a domestic insurance company is not exempt under R.C. 5725.25 from the franchise tax imposed by R.C. Chapter 5733.

*60R.C. 5725.25 is an exemption statute which must be strictly construed against the taxpayer. Celina Mut. Ins. Co. v. Bowers (1965), 5 Ohio St.2d 12, 34…