IRS supplements interest rate schedules for insurance reserve computation.
Rev. Rul. 2011-23; 2011-43 I.R.B. 585
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- Tax Analysts Document NumberDoc 2011-21304
- Tax Analysts Electronic Citation2011 TNT 196-18
Part I
Section 807. -- Rules for Certain Reserves
For purposes of § 807(d)(4) of the Internal Revenue Code, for taxable years beginning after December 31, 2009, this ruling supplements the schedules of prevailing state assumed interest rates set forth in Rev. Rul. 92-19, 1992-1 C.B. 227. This information is to be used by insurance companies in computing their reserves for (1) life insurance and supplementary total and permanent disability benefits, (2) individual annuities and pure endowments, and (3) group annuities and pure endowments. As § 807(d)(2)(B) requires that the interest rate used to compute these reserves be the greater of (1) the applicable federal interest rate, or (2) the prevailing state assumed interest rate, the table of applicable federal interest rates in Rev. Rul. 92-19 is also supplemented.
Following are supplements to schedules A, B, C, and D to Part III of Rev. Rul. 92-19, providing prevailing state assumed interest rates for insurance products with different features issued in 2010 and 2011, and a supplement to the table in Part IV of Rev. Rul. 92-19, providing the applicable federal interest rates under § 807(d) for 2010 and 2011. This ruling does not supplement Parts I and II of Rev. Rul. 92-19.
This is the nineteenth supplement to the interest rates provided in Rev. Rul. 92-19. Earlier supplements were published in Rev. Rul. 93-58, 1993-2 C.B. 241 (interest rates for insurance products issued in 1992 and 1993); Rev. Rul. 94-11, 1994-1 C.B. 196 (1993 and 1994); Rev. Rul. 95-4, 1995-1 C.B. 141 (1994 and 1995); Rev. Rul. 96-2, 1996-1 C.B. 141 (1995 and 1996); Rev. Rul. 97-2, 1997-1 C.B. 134 (1996 and 1997); Rev. Rul. 98-2, 1998-1 C.B. 259 (1997 and 1998); Rev. Rul. 99-10, 1999-1 C.B. 671 (1998 and 1999); Rev. Rul. 2000-17, 2000-1 C.B. 842 (1999 and 2000); Rev. Rul. 2001-11, 2001-1 C.B. 780 (2000 and 2001); Rev. Rul. 2002-12, 2002-1 C.B. 624 (2001 and 2002); Rev. Rul. 2003-24, 2003-1 C.B. 557 (2002 and 2003); Rev. Rul. 2004-14, 2004-1 C.B. 511 (2003 and 2004); Rev. Rul. 2005-29, 2005-1 C.B. 1080 (2004 and 2005); Rev. Rul. 2006-25, 2006-1 C.B. 882 (2005 and 2006); Rev. Rul. 2007-10, 2007-1 C.B. 660 (2006 and 2007); Rev. Rul. 2008-19, 2008-1 C.B. 669 (2007 and 2008); Rev. Rul. 2009-3, 2009-5 I.R.B. 382 (2008 and 2009); and Rev. Rul. 2010-7, 2010-8 I.R.B. 417 (2009 and 2010).
Part III. Prevailing State Assumed Interest Rates -- Products Issued in Years After 1982.*
Schedule A
STATUTORY VALUATION INTEREST RATES
BASED ON THE 1980 AMENDMENTS TO THE
NAIC STANDARD VALUATION LAW
A. Life insurance valuation:
______________________________________________________________________________
Guarantee Duration (years) Calendar Year of Issue 2011
______________________________________________________________________________
10 or fewer 4.50**
More than 10 but not more than 20 4.25**
More than 20 4.00**
______________________________________________________________________________
Source: Rates calculated from the monthly averages, ending June 30, 2010, of
Moody's Composite Yield on Seasoned Corporate Bonds.
* The terms used in the schedules in this ruling and in Part III of Rev.
Rul. 92-19 are those used in the Standard Valuation Law; the terms are defined
in Rev. Rul. 92-19.
** As these rates exceed the applicable federal interest rate for 2011 of
3.46 percent, the valuation interest rate to be used for this product under
§ 807 is the applicable rate specified in this table.
STATUTORY VALUATION INTEREST RATES
BASED ON THE 1980 AMENDMENTS TO THE
NAIC STANDARD VALUATION LAW
B. Single premium immediate annuities and annuity benefits involving life contingencies arising from other annuities with cash settlement options and from guaranteed interest contracts with cash settlement options:
______________________________________________________________________________
Calendar Year of Issue Valuation Interest Rate
______________________________________________________________________________
2010 5.25*
______________________________________________________________________________
Source: Rates calculated from the monthly averages, ending June 30, 2010, of
Moody's Composite Yield on Seasoned Corporate Bonds (formerly known as Moody's
Corporate Bond Yield Average -- Monthly Average Corporates). The terms used in
this schedule are those used in the Standard Valuation Law as defined in Rev.
Rul. 92-19.
* As this prevailing state assumed interest exceeds the applicable
federal interest rate for 2010 of 3.81 percent, the valuation interest rate of
5.25 percent is to be used for this product under § 807.
STATUTORY VALUATION INTEREST RATES
BASED ON NAIC STANDARD VALUATION LAW
FOR 2010 CALENDAR YEAR BUSINESS
GOVERNED BY THE 1980 AMENDMENTS
C. Valuation interest rates for other annuities and guaranteed interest contracts that are valued on an issue year basis:
______________________________________________________________________________
Valuation Interest Rate (%)
For Plan Type
Cash Future ___________________________
Settlement Interest Guarantee Duration
Options? Guarantee? (years) A B C
______________________________________________________________________________
Yes Yes 5 or fewer 5.25* 4.75* 4.25*
More than 5, but not 5.00* 4.75* 4.25*
more than 10
More than 10, but not 4.75* 4.25* 4.25*
more than 20
More than 20 4.25* 4.00* 4.00*
Yes No 5 or fewer 5.25* 4.75* 4.50*
More than 5, but not 5.25* 4.75* 4.50*
more than 10
More than 10, but not 5.00* 4.50* 4.25*
more than 20
More than 20 4.25* 4.00* 4.00*
No Yes or No 5 or fewer 5.25*
More than 5, but not 5.00* NOT
more than 10 APPLICABLE
More than 10, but not 4.75*
more than 20
More than 20 4.25*
______________________________________________________________________________
Source: Rates calculated from the monthly averages, ending June 30, 2010, of
Moody's Composite Yield on Seasoned Corporate Bonds.
* As these rates exceed the applicable federal interest rate for 2010 of
3.81 percent, the valuation interest rate to be used for this product under
§ 807 is the applicable rate specified in the above table.
STATUTORY VALUATION INTEREST RATES
BASED ON NAIC STANDARD VALUATION LAW
FOR 2010 CALENDAR YEAR BUSINESS
GOVERNED BY THE 1980 AMENDMENTS
D. Valuation interest rates for other annuities and guaranteed interest contracts that are contracts with cash settlement options and that are valued on a change in fund basis:
______________________________________________________________________________
Valuation Interest Rate (%)
For Plan Type
Cash Future ___________________________
Settlement Interest Guarantee Duration
Options? Guarantee? (years) A B C
______________________________________________________________________________
Yes Yes 5 or fewer 5.50 5.25 4.50
More than 5, but not 5.50 5.25 4.50
more than 10
More than 10, but not 5.25 5.00 4.25
more than 20
More than 20 4.75 4.75 4.00*
Yes No 5 or fewer 5.75 5.50 4.75
More than 5, but not 5.50 5.50 4.75
more than 10
More than 10, but not 5.25 5.25 4.50
more than 20
More than 20 4.75 4.75 4.25*
______________________________________________________________________________
Source: Rates calculated from the monthly averages, ending June 30, 2010, of
Moody's Composite Yield on Seasoned Corporate Bonds.
* As the applicable federal interest rate for 2010 of 3.81 percent is
less than the prevailing state assumed interest rate, the valuation interest
rate to be used for this product under § 807 is the applicable rate
specified in the above table.
TABLE OF
APPLICABLE FEDERAL INTEREST RATES
FOR PURPOSES OF § 807
______________________________________________________________________
Year Interest Rate
______________________________________________________________________
2010 3.81
2011 3.46
______________________________________________________________________
Sources: Rev. Rul. 2004-106, 2004-2 C.B. 893, for the 2005 rate; Rev.
Rul. 2005-77, 2005-2 C.B. 1071, for the 2006 rate; Rev. Rul. 2006-61,
2006-2 C.B 1028 for the 2007 rate; Rev. Rul. 2007-70, 2007-2 C.B.
1158 for the 2008 rate; Rev. Rul. 2008-53, 2008-49 I.R.B. 1231 for
the 2009 rate; Rev. Rul. 2009-38, 2009-49 I.R.B. 736 for the 2010
rate; and Rev. Rul. 2010-29, 2010-50 I.R.B. 818 for the 2011 rate. .
EFFECT ON OTHER REVENUE RULINGS
Rev. Rul. 92-19 is supplemented by the addition to Part III of that ruling of prevailing state assumed interest rates under § 807 for certain insurance products issued in 2010 and 2011 and is further supplemented by an addition to the table in Part IV of Rev. Rul. 92-19 listing applicable federal interest rates. Parts I and II of Rev. Rul. 92-19 are not affected by this ruling.
DRAFTING INFORMATION
The principal author of this revenue ruling is Linda K. Boyd of the Office of Associate Chief Counsel (Financial Institutions and Products). For further information regarding this revenue ruling contact her at (202) 622-3970 (not a toll-free call).
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Areas/Tax Topics
- Jurisdictions
- LanguageEnglish
- Tax Analysts Document NumberDoc 2011-21304
- Tax Analysts Electronic Citation2011 TNT 196-18