current A-plus (superior) rating on ice last week until further notice. AM Best Co. announced the rating was "under review with developing implications'' after last week's US tax court ruling against OPL's former big brother company United Parcel Service. The agency is scheduled to meet with OPL head honchos to settle how the rating should stand.

The shock tax court ruling requires UPS to pay taxes, penalties and interest to the US Internal Revenue service for claiming a 1984 deduction related to its use of OPL, which the judge found was out of order. For that year alone, pundits have estimated the IRS bill totals as much as $300 million.

But the IRS is expected to file claims against UPS for subsequent years since the company has continued the use what the judge described as a "sham transaction'' to reduce its tax. UPS has denied any wrongdoing and may appeal the decision.

DEBT OFFERING BUC Debt offering The holding company of Bermuda insurance giant ACE Limited has priced an $800 million debt offering, it has been announced.

The offering is made up of $400 million worth of 8.2 percent notes due 2004 along with $300 million of 8.3 percent notes due 2006 and $100 million of 8.875 percent debentures due 2029. The net proceeds from the offering of the debt securities will be used to repay commercial paper. This represents a portion of the interim financing used by ACE to buy the property and casualty business of US-based CIGNA Corporation, now known as ACE INA Holdings Inc., in the $3 billion cash deal finalised last month.

Merrill Lynch & Co. teamed up with Chase Securities Inc. to manage the offerings.

AM Best Co. has assigned an "a'' senior debt rating to $800 million of new unsecured senior debt obligations issued by ACE INA Holdings.