Any transaction entered into by a mutual insurer, either during or after the reorganization process authorized by sections 19F to 19W, inclusive, a principal purpose of which is to avoid the total gross investment income earned excise imposed by section 22A of chapter 63 or the investment privilege excise imposed by section 22B of said chapter 63 shall be disregarded by the department of revenue for purposes of computing said excise for the reorganized insurer. The department of revenue, in consultation with the division of insurance, shall promulgate rules and regulations necessary to implement the provisions of this section, and may consult with representatives of the insurance industry and practitioners.
Mass. Gen. Laws ch. 175, § 19V