26 C.F.R. § 1.846-0   Outline of provisions.


Title 26 - Internal Revenue


Title 26: Internal Revenue
PART 1—INCOME TAXES
Other Insurance Companies

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§ 1.846-0   Outline of provisions.

The following is a list of the headings in §§1.846–1 through 1.846–4.

§1.846–1 Application of discount factors.

(a) In general.

(1) Rules.

(2) Examples.

(3) Increase in discounted unpaid losses shown on the annual statement.

(4) Increase in unpaid losses which take into account estimated salvage recoverable.

(b) Applicable discount factors.

(1) In general.

(i) Discount factors published by the Service.

(ii) Composite discount factors.

(iii) Annual statement changes.

(2) Title insurance company reserves.

(3) Reinsurance business.

(i) Proportional reinsurance for accident years after 1987.

(ii) Non-proportional reinsurance.

(A) Accident years after 1991.

(B) Accident years 1988 through 1991.

(iii) Reinsurance for accident years before 1988.

(iv) 90 percent exception.

(4) International business.

(5) Composite discount factors.

§1.846–2 Election by taxpayer to use its own historical loss payment pattern.

(a) In general.

(b) Eligible line of business.

(1) In general.

(2) Other published guidance.

(3) Special rule for 1987 determination year.

(c) Anti-abuse rule.

(d) Effect of section 338 election on section 846(e) election.

§1.846–2T  Election by taxpayer to use its own historical loss payment pattern (temporary).

(a) through (c) [Reserved]

(d) Effect of section 338 election on section 846(e) election.

§1.846–3 Fresh start and reserve strengthening.

(a) In general.

(b) Applicable discount factors.

(1) Calculation of beginning balance.

(2) Example.

(c) Rules for determining the amount of reserve strengthening.

(1) In general.

(2) Accident years after 1985.

(i) In general.

(ii) Hypothetical unpaid loss reserve.

(3) Accident years before 1986.

(i) In general.

(ii) Exceptions.

(iii) Certain transactions deemed to be reinsurance assumed (ceded) in 1986.

(d) Section 845.

(e) Treatment of reserve strengthening.

(f) Examples.

§1.846–4  Effective dates.

(a) In general.

(b) Section 338 election.

§1.846–4T  Effective dates (temporary).

(a) [Reserved]

(b) Section 338 election.

[T.D. 8433, 57 FR 40843, Sept. 8, 1992; 57 FR 48563, Oct. 27, 1992; T.D. 9257, 71 FR 18005, Apr. 10, 2006]

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