us-irs-revenue-procedures-rp-10-50•rp-10-50.pdf
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Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.201: Rulings and determination letters. (Also Part I, Sections 832, 846; 1.832-4, 1.846-1.) Rev. Proc. 2010-50 SECTION 1. PURPOSE This revenue procedure prescribes the salvage discount factors for the 2010 accident year. These factors must be used to compute discounted estimated salvage recoverable under § 832 of the Internal Revenue Code. SECTION 2. BACKGROUND Section 832(b)(5)(A) requires that all estimated salvage recoverable (including that which cannot be treated as an asset for state accounting purposes) be taken into account in computing the deduction for losses incurred. Under § 832(b)(5)(A), paid losses are to be reduced by salvage and reinsurance recovered during the taxable year. This amount is adjusted to reflect changes in discounted unpaid losses on nonlife insurance contracts and in unpaid losses on life insurance contracts. An adjustment is then made to reflect any changes in discounted estimated salvage recoverable and in reinsurance recoverable. 2 Pursuant to § 832(b), the amount of estimated salvage is determined on a discounted basis in accordance with procedures established by the Secretary. SECTION 3. SCOPE This revenue procedure applies to any taxpayer that is required to discount estimated salvage recoverable under § 832. SECTION 4. APPLICATION .01 The following tables present separately for each line of business the discount factors under § 832 for the 2010 accident year. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 2010, which is 3.81 percent, and by assuming all estimated salvage is recovered in the middle of each calendar year. See Rev. Proc. 2008-11, 2008-1 C.B. 301, for background regarding the tables. .02 These tables must be used by taxpayers irrespective of whether they elected to discount unpaid losses using their own historical experience under § 846. 3 .03 Section V of Notice 88-100, 1988-2 C.B. 439, provides a composite discount factor to be used in determining the discounted unpaid losses for accident years that are not separately reported on the annual statement approved by the National Association of Insurance Commissioners. The tables separately provide discount factors for taxpayers who elect to use the composite method. Rev. Proc. 2002-74, 2002-2 C.B. 980, clarifies that for certain insurance companies subject to tax under § 831 the composite method for discounting unpaid losses set forth in Notice 88-100, section V, is permitted but not required. This revenue procedure further provides alternative methods for computing discounted unpaid losses that are permitted for insurance companies not using the composite method, and sets forth a procedure for insurance companies to obtain automatic consent of the Commissioner to change to one of the methods described in Rev. Proc. 2002-74. 4 .04 Tables. Tables of Factors to be Used to Discount Salvage Recoverable With Respect to Losses Incurred in Accident Year 2010 (Interest rate: 3.81 percent) Lines of Business Accident and Health (Other Than Disability Income or Credit Disability Insurance) Taxpayers that do not use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable with respect to losses incurred in this line of business in the 2010 accident year as of the end of the 2010 and later taxable years. Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount all salvage recoverable in this line of business as of the end of the 2010 taxable year. Auto Physical Damage Discount Tax Year Factors (%) 2010 97.3968 2011 96.3467 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2012 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2012 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 5 Commercial Auto/Truck Liability/Medical Discount Tax Year Factors (%) 2010 92.7837 2011 92.7323 2012 93.0580 2013 93.3885 2014 94.0857 2015 93.8868 2016 92.4123 2017 93.2791 2018 96.4600 2019 98.1478 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 6 Composite Discount Tax Year Factors (%) 2010 92.7966 2011 92.5582 2012 92.3906 2013 92.2259 2014 91.6392 2015 90.7679 2016 91.5729 2017 92.8475 2018 94.7606 2019 96.4814 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1394 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 7 Fidelity/Surety Discount Tax Year Factors (%) 2010 94.0623 2011 96.3467 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2012 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2012 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 8 Financial Guaranty/Mortgage Guaranty Discount Tax Year Factors (%) 2010 95.0489 2011 96.3467 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2012 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2012 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 9 International (Composite) Discount Tax Year Factors (%) 2010 92.7966 2011 92.5582 2012 92.3906 2013 92.2259 2014 91.6392 2015 90.7679 2016 91.5729 2017 92.8475 2018 94.7606 2019 96.4814 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1394 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 10 Medical Malpractice -- Claims-Made Discount Tax Year Factors (%) 2010 93.0786 2011 94.0952 2012 92.5904 2013 93.1817 2014 92.5233 2015 88.3749 2016 85.2082 2017 90.8503 2018 96.6547 2019 98.1478 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 11 Medical Malpractice -- Occurrence Discount Tax Year Factors (%) 2010 86.3162 2011 90.4919 2012 92.7220 2013 85.1582 2014 95.0887 2015 91.9139 2016 93.4195 2017 96.1175 2018 97.2711 2019 98.1478 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 12 Miscellaneous Casualty Discount Tax Year Factors (%) 2010 96.7847 2011 96.3467 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2012 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2012 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 13 Multiple Peril Lines (Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability (Ocean Marine, Aircraft (All Perils), Boiler and Machinery)) Discount Tax Year Factors (%) 2010 93.4004 2011 92.8257 2012 92.7508 2013 92.6906 2014 91.9254 2015 90.4434 2016 91.5362 2017 93.8270 2018 95.1497 2019 96.8145 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 14 Other (Including Credit) Discount Tax Year Factors (%) 2010 95.8998 2011 96.3467 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2012 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2012 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 15 Other Liability -- Claims-Made Discount Tax Year Factors (%) 2010 89.0574 2011 90.1163 2012 88.3414 2013 91.3936 2014 92.7947 2015 94.5684 2016 93.5605 2017 92.2516 2018 97.5182 2019 98.1478 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 16 Other Liability -- Occurrence Discount Tax Year Factors (%) 2010 87.8282 2011 88.8138 2012 91.0169 2013 91.7356 2014 91.2069 2015 91.3193 2016 90.8227 2017 93.4080 2018 96.0113 2019 97.7168 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 17 Private Passenger Auto Liability/Medical Discount Tax Year Factors (%) 2010 94.8467 2011 94.8695 2012 94.6345 2013 93.8178 2014 93.2668 2015 92.5396 2016 93.3887 2017 94.8601 2018 94.9293 2019 96.6211 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 18 Products Liability -- Claims-Made Discount Tax Year Factors (%) 2010 89.5111 2011 53.8777 2012 56.2338 2013 91.2109 2014 81.2016 2015 91.8947 2016 61.7067 2017 91.0293 2018 92.1071 2019 93.1849 Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 94.8773 2021 96.5773 2022 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 95.8305 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 19 Products Liability -- Occurrence Discount Tax Year Factors (%) 2010 88.3200 2011 90.2935 2012 92.0747 2013 92.8492 2014 93.2720 2015 90.9592 2016 91.5621 2017 94.3528 2018 94.6093 2019 96.3618 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1145 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 20 Reinsurance -- Nonproportional Assumed Property Discount Tax Year Factors (%) 2010 91.5967 2011 93.1520 2012 95.9361 2013 81.1923 2014 90.4025 2015 82.5156 2016 54.0401 2017 93.2324 2018 74.7782 2019 88.7685 Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 90.4287 2021 92.1524 2022 93.9603 2023 95.9026 2024 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 92.3206 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 21 Reinsurance -- Nonproportional Assumed Liability Discount Tax Year Factors (%) 2010 87.4907 2011 90.5937 2012 91.9716 2013 89.2639 2014 91.2258 2015 92.0480 2016 91.9513 2017 93.6177 2018 95.4465 2019 97.0969 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.0840 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 22 Reinsurance -- Nonproportional Assumed Financial Lines Discount Tax Year Factors (%) 2010 87.8550 2011 86.6634 2012 90.4544 2013 79.6749 2014 90.7909 2015 81.3855 2016 90.9640 2017 91.3553 2018 97.6631 2019 98.1478 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 23 Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary and Theft) Discount Tax Year Factors (%) 2010 95.1830 2011 96.3467 Taxpayers that do not use the composite method of Notice 88-100 should use the following factor to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2012 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 98.1478 percent to discount salvage recoverable as of the end of the 2012 taxable year with respect to losses incurred in this line of business in 2010 and prior years. 24 Workers' Compensation Discount Tax Year Factors (%) 2010 89.0169 2011 90.9477 2012 91.7039 2013 91.6235 2014 90.2053 2015 88.8704 2016 89.4375 2017 89.1742 2018 91.2385 2019 92.9096 Taxpayers that do not use the composite method of Notice 88-100 should use the following factors to discount salvage recoverable as of the end of the tax year shown with respect to losses incurred in this line of business in the 2010 accident year. 2020 94.6208 2021 96.3708 2022 and later years 98.1478 Taxpayers that use the composite method of Notice 88-100 should use 95.6888 percent to discount salvage recoverable as of the end of the 2020 taxable year with respect to losses incurred in this line of business in 2010 and prior years. DRAFTING INFORMATION The principal author of this revenue procedure is Sarah E. Swan of the Office of the Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure, contact Ms. Swan at (202)622-8443 (not a toll free call).
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