IRS Issues Unpaid Loss and Salvage Discount Factors for 2020
Rev. Proc. 2020-48; 2020-48 IRB 1459
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Areas/Tax Topics
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- Tax Analysts Document Number2020-43371
- Tax Analysts Electronic Citation2020 TNTF 214-182020 TPR 45-7
26 CFR 601.201: Rulings and determination letters.
(Also: Part I, Sections 832, 846; 1.832-4, 1.846-1.)
SECTION 1. PURPOSE
This revenue procedure prescribes discount factors for the 2020 accident year for use by insurance companies in computing discounted unpaid losses under § 846 of the Internal Revenue Code and discounted estimated salvage recoverable under § 832. This revenue procedure also provides, for convenience, discount factors for losses incurred in the 2019 accident year and earlier accident years for use in taxable years beginning in 2020. The discount factors for accident years before 2020 were prescribed in Rev. Proc. 2019-31, 2019-33 I.R.B. 643. See Rev. Proc. 2019-31 and Rev. Proc. 2019-06, 2019-02 IRB 284, for background concerning the loss payment patterns and application of the discount factors.
SECTION 2. SCOPE
This revenue procedure applies to any insurance company that is required to discount unpaid losses under § 846 for a line of business using the discount factors published by the Secretary, and also applies to any insurance company that is required to discount estimated salvage recoverable under § 832.
SECTION 3. DISCOUNT FACTORS FOR THE 2020 ACCIDENT YEAR
.01 The tables in this section 3 present separately for each line of business the discount factors for losses incurred in the 2020 accident year for use by insurance companies in computing discounted unpaid losses under § 846 and estimated salvage recoverable under § 832. All of the discount factors presented in these tables are determined by using the applicable interest rate for 2020 under § 846(c), which is 3.08 percent, compounded semiannually, and the payment patterns for the 2017 determination year determined by the Secretary under § 846(d). All of the discount factors presented in these tables are determined by assuming all loss payments occur in the middle of the calendar year.
.02 Section V of Notice 88-100, 1988-2 C.B. 439, sets forth a composite method for computing discounted unpaid losses for accident years that are not separately reported on the annual statement. Tables 1 and 2 separately provide discount factors for insurance companies that have elected to use the composite method of Notice 88-100. See Rev. Proc. 2002-74, 2002-2 C.B. 980. The discount factors computed using the composite method are unrelated to the composite discount factors referred to in § 1.846-1(b)(1)(ii) and (4) of the Income Tax Regulations, which apply to lines of business for which the Secretary has not published discount factors. The composite discount factors for use with respect to such lines of business are labelled “Short-Tail Composite” (in Table 1, part B) and “Long-Tail Composite” (in Table 2, part B). The “Miscellaneous Casualty” discount factors referenced in § 1.846-1(b)(2) are not set forth in tables, but are equivalent to the “Short-Tail Composite” discount factors.
Taxable Year Beginning in | Auto Physical Damage | Fidelity/Surety | Financial Guaranty/Mortgage Guaranty | International | Other* |
---|---|---|---|---|---|
2020 | 98.3139 | 95.8052 | 95.5582 | 96.1310 | 96.9677 |
2021 | 97.0010 | 97.0010 | 97.0010 | 97.0010 | 97.0010 |
Taxpayer Not Using Composite Method | |||||
Years after 2021 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 |
Taxpayer Using the Composite Method | |||||
2022 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 |
Years after 2022 | Use composite discount factors published for the relevant accident year.** | ||||
* For Accident and Health lines of business (other than disability income or credit disability insurance), the discount factor for taxable year 2020 is 98.4834 percent. For later years, the discount factor for losses incurred in 2020 is the discount factor published for Accident and Health lines of business for losses incurred in the accident year coinciding with the taxable year. ** The relevant accident year is the accident year that is two years prior to the specified taxable year. |
Taxable Year Beginning in | Reinsurance — Nonproportional Assumed Liability | Reinsurance — Nonproportional Assumed Property | Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary & Theft) | Warranty | Short-Tail Composite |
---|---|---|---|---|---|
2020 | 94.6016 | 96.1125 | 97.3985 | 98.1106 | 96.8566 |
2021 | 97.0010 | 97.0010 | 97.0010 | 97.0010 | 97.0010 |
Taxpayer Not Using Composite Method | |||||
Years after 2021 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 |
Taxpayer Not Using Composite Method | |||||
2022 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 |
Years after 2022 | Use composite discount factors published for the relevant accident year.** | ||||
** The relevant accident year is the accident year that is two years prior to the specified taxable year. |
Taxable Year Beginning in | Commercial Auto/Truck Liability/Medical | Medical Professional Liability — Claims-Made | Medical Professional Liability — Occurrence | Multiple Peril Lines | Other Liability — Claims-Made | Other Liability — Occurrence |
---|---|---|---|---|---|---|
2020 | 93.7894 | 91.2887 | 86.3302 | 95.0975 | 90.4958 | 88.9133 |
2021 | 94.5252 | 92.3148 | 88.4733 | 93.3939 | 91.3319 | 89.7843 |
2022 | 95.0694 | 92.5421 | 90.0641 | 93.7004 | 91.8577 | 90.3548 |
2023 | 95.1096 | 92.8346 | 91.4580 | 92.9075 | 91.9007 | 90.5269 |
2024 | 94.9861 | 92.9813 | 92.4445 | 91.0317 | 91.7488 | 90.2789 |
2025 | 94.8262 | 93.0034 | 93.2158 | 91.2360 | 92.2753 | 90.3502 |
2026 | 95.1140 | 93.9822 | 94.0622 | 90.9324 | 92.7671 | 90.3726 |
2027 | 94.7512 | 94.9071 | 94.7714 | 90.6175 | 93.5594 | 91.6265 |
2028 | 96.2444 | 95.8327 | 95.9435 | 93.2279 | 94.6947 | 92.2914 |
2029 | 98.2817 | 97.6457 | 97.6874 | 94.6187 | 96.5347 | 94.2474 |
Taxpayer Not Using Composite Method | ||||||
2030 | 98.4834 | 98.4834 | 98.4834 | 96.0142 | 97.9102 | 95.6606 |
2031
| 98.4834 | 98.4834 | 98.4834 | 97.3886 | 98.4834 | 97.0886 |
Years after 2031 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 |
Taxpayer Using the Composite Method | ||||||
2030 | 98.4834 | 98.4834 | 98.4834 | 96.7819 | 98.0023 | 96.5869 |
Years after 2030 | Use composite discount factors published for the relevant accident year.* | |||||
* The relevant accident year is the accident year that is ten years prior to the specified taxable year. |
Taxable Year Beginning in | Private Passenger Auto Liability/Medical | Products Liability — Claims-Made | Products Liability — Occurrence | Workers' Compensation | Long-Tail Composite |
---|---|---|---|---|---|
2020 | 95.4796 | 85.3166 | 87.3013 | 87.5556 | 92.4450 |
2021 | 95.0805 | 85.7949 | 88.6772 | 85.9962 | 91.3753 |
2022 | 95.0391 | 87.6480 | 89.4512 | 84.8651 | 91.0823 |
2023 | 94.6635 | 83.1315 | 90.8125 | 83.3180 | 89.8805 |
2024 | 93.9744 | 84.4598 | 89.4430 | 82.7387 | 88.2753 |
2025 | 94.0255 | 85.8393 | 89.4917 | 82.1898 | 88.1551 |
2026 | 94.2730 | 87.2786 | 90.4502 | 82.5646 | 88.1342 |
2027 | 94.8300 | 88.5618 | 91.4434 | 83.4400 | 88.6931 |
2028 | 95.4472 | 89.8703 | 91.8491 | 84.0701 | 89.9615 |
2029 | 97.6225 | 91.2045 | 94.1596 | 86.0229 | 91.7954 |
Taxpayer Not Using Composite Method | |||||
2030 | 98.4834 | 92.5645 | 95.5800 | 87.2812 | 93.1592 |
2031 | 98.4834 | 93.9501 | 97.0253 | 88.5644 | 94.5437 |
2032 | 98.4834 | 95.3597 | 98.4834 | 89.8730 | 95.9411 |
2033 | 98.4834 | 96.7878 | 98.4834 | 91.2073 | 97.3233 |
2034 | 98.4834 | 98.2068 | 98.4834 | 92.5675 | 98.4834 |
2035 | 98.4834 | 98.4834 | 98.4834 | 93.9532 | 98.4834 |
2036 | 98.4834 | 98.4834 | 98.4834 | 95.3630 | 98.4834 |
2037 | 98.4834 | 98.4834 | 98.4834 | 96.7916 | 98.4834 |
2038 | 98.4834 | 98.4834 | 98.4834 | 98.2114 | 98.4834 |
Years after 2038 | 98.4834 | 98.4834 | 98.4834 | 98.4834 | 98.4834 |
Taxpayer Using the Composite Method | |||||
2030 | 98.4834 | 94.5507 | 96.5457 | 91.0641 | 94.9230 |
Years after 2030 | Use composite discount factors published for the relevant accident year.* | ||||
* The relevant accident year is the accident year that is ten years prior to the specified taxable year. |
SECTION 4. DISCOUNT FACTORS FOR TAXABLE YEARS BEGINNING IN 2020
.01 The tables in this section 4 present separately for each line of business discount factors for losses incurred in the 2020 accident year and earlier accident years for use by insurance companies in computing discounted unpaid losses under § 846 and estimated salvage recoverable under § 832 in taxable years beginning in 2020. The discount factors for losses incurred in accident years 2019 and 2020 presented in these tables are determined by using the applicable interest rate for 2019 (3.09 percent, compounded semiannually) and 2020 (3.08 percent, compounded semiannually), respectively, under § 846(c). All other discount factors presented in these tables are determined by using the applicable interest rate for 2018, which is 2.94 percent, compounded semiannually. All of the discount factors presented in these tables are determined by using the payment patterns for the 2017 determination year determined by the Secretary under § 846(d) and by assuming all loss payments occur in the middle of the calendar year. See Rev. Proc. 2019-31 (prescribing discount factors for the 2019 accident year and “Revised Discount Factors” for accident years beginning before 2019).
.02 Table 4 separately provides discount factors for insurance companies that have elected to use the composite method of Notice 88-100. See Rev. Proc. 2002-74. The discount factors computed using the composite method are unrelated to the composite discount factors referred to in § 1.846-1(b)(1)(ii) and (4), which apply to lines of business for which the Secretary has not published discount factors. The composite discount factors for use with respect to such lines of business are labelled “Short-Tail Composite” (in Table 3, part B) and “Long-Tail Composite” (in Table 4, part B). The “Miscellaneous Casualty” discount factors referenced in § 1.846-1(b)(2) are not set forth in tables, but are equivalent to the “Short-Tail Composite” discount factors.
Accident Year | Auto Physical Damage | Fidelity/Surety | Financial Guaranty/Mortgage Guaranty | International | Other* |
---|---|---|---|---|---|
2020 | 98.3139 | 95.8052 | 95.5582 | 96.1310 | 96.9677 |
2019 | 96.9916 | 96.9916 | 96.9916 | 96.9916 | 96.9916 |
Years before 2019 | 98.5513 | 98.5513 | 98.5513 | 98.5513 | 98.5513 |
* For Accident and Health lines of business (other than disability income or credit disability insurance), the discount factor for taxable year 2020 is 98.4834 percent. |
Accident Year | Reinsurance — Nonproportional Assumed Financial Lines | Reinsurance — Nonproportional Assumed Liability | Reinsurance — Nonproportional Assumed Property | Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Burglary & Theft) | Warranty | Short-Tail Composite |
---|---|---|---|---|---|---|
2020 | 95.4035 | 94.6016 | 96.1125 | 97.3985 | 98.1106 | 96.8566 |
2019 | 96.9916 | 96.9916 | 96.9916 | 96.9916 | 96.9916 | 96.9916 |
Years before 2019 | 98.5513 | 98.5513 | 98.5513 | 98.5513 | 98.5513 | 98.5513 |
Accident Year | Commercial Auto/Truck Liability/Medical | Medical Professional Liability — Claims-Made | Medical Professional Liability — Occurrence | Multiple Peril Lines | Other Liability — Claims-Made | Other Liability — Occurrence |
---|---|---|---|---|---|---|
2020 | 93.7894 | 91.2887 | 86.3302 | 95.0975 | 90.4958 | 88.9133 |
2019 | 94.5084 | 92.2917 | 88.4392 | 93.3741 | 91.3061 | 89.7544 |
2018 | 95.2819 | 92.8576 | 90.4811 | 93.9651 | 92.1992 | 90.7535 |
2017 | 95.3204 | 93.1388 | 91.8194 | 93.2041 | 92.2415 | 90.9196 |
2016 | 95.2024 | 93.2805 | 92.7664 | 91.4064 | 92.0976 | 90.6836 |
2015 | 95.0498 | 93.3035 | 93.5069 | 91.6039 | 92.6040 | 90.7542 |
2014 | 95.3260 | 94.2423 | 94.3189 | 91.3154 | 93.0770 | 90.7788 |
2013 | 94.9804 | 95.1291 | 94.9993 | 91.0177 | 93.8378 | 91.9830 |
2012 | 96.4102 | 96.0160 | 96.1220 | 93.5200 | 94.9264 | 92.6228 |
2011 | 98.3585 | 97.7503 | 97.7902 | 94.8530 | 96.6876 | 94.4974 |
Taxpayer Not Using the Composite Method | ||||||
2010 | 98.5513 | 98.5513 | 98.5513 | 96.1895 | 98.0033 | 95.8511 |
2009 | 98.5513 | 98.5513 | 98.5513 | 97.5045 | 98.5513 | 97.2176 |
Years before 2009 | 98.5513 | 98.5513 | 98.5513 | 98.5513 | 98.5513 | 98.5513 |
Taxpayer Using the Composite Method | ||||||
Years before 2011 | 98.5513 | 98.5513 | 98.5513 | 96.9185 | 98.0920 | 96.7300 |
Accident Year | Private Passenger Auto Liability/Medical | Products Liability — Claims-Made | Products Liability — Occurrence | Workers' Compensation | Long-Tail Composite |
---|---|---|---|---|---|
2020 | 95.4796 | 85.3166 | 87.3013 | 87.5556 | 92.4450 |
2019 | 95.0654 | 85.7548 | 88.6442 | 85.9577 | 91.3501 |
2018 | 95.2520 | 88.1407 | 89.8860 | 85.4517 | 91.4469 |
2017 | 94.8920 | 83.8076 | 91.1924 | 83.9662 | 90.2933 |
2016 | 94.2325 | 85.0889 | 89.8810 | 83.4129 | 88.7546 |
2015 | 94.2824 | 86.4184 | 89.9309 | 82.8905 | 88.6421 |
2014 | 94.5205 | 87.8040 | 90.8527 | 83.2567 | 88.6258 |
2013 | 95.0550 | 89.0388 | 91.8072 | 84.1036 | 89.1661 |
2012 | 95.6473 | 90.2969 | 92.1992 | 84.7150 | 90.3858 |
2011 | 97.7282 | 91.5785 | 94.4133 | 86.5946 | 92.1457 |
Taxpayer Not Using the Composite Method | |||||
2010 | 98.5513 | 92.8838 | 95.7739 | 87.8065 | 93.4541 |
2009 | 98.5513 | 94.2124 | 97.1571 | 89.0414 | 94.7812 |
2008 | 98.5513 | 95.5629 | 98.5513 | 90.2995 | 96.1195 |
2007 | 98.5513 | 96.9299 | 98.5513 | 91.5813 | 97.4421 |
2006 | 98.5513 | 98.2868 | 98.5513 | 92.8867 | 98.5513 |
2005 | 98.5513 | 98.5513 | 98.5513 | 94.2154 | 98.5513 |
2004 | 98.5513 | 98.5513 | 98.5513 | 95.5661 | 98.5513 |
2003 | 98.5513 | 98.5513 | 98.5513 | 96.9334 | 98.5513 |
2002 | 98.5513 | 98.5513 | 98.5513 | 98.2913 | 98.5513 |
Years before 2002 | 98.5513 | 98.5513 | 98.5513 | 98.5513 | 98.5513 |
Taxpayer Using the Composite Method | |||||
Years before 2011 | 98.5513 | 94.7288 | 96.6903 | 91.2579 | 95.0968 |
SECTION 5. DRAFTING INFORMATION
The principal author of this revenue procedure is Megan McGuire of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure contact Ms. McGuire at (202) 317-6995 (not a toll-free call).
- Institutional AuthorsInternal Revenue Service
- Code Sections
- Subject Areas/Tax Topics
- Jurisdictions
- Tax Analysts Document Number2020-43371
- Tax Analysts Electronic Citation2020 TNTF 214-182020 TPR 45-7