Rev. Proc. 2008-11
Rev. Proc. 2008-11
in: Rev. Proc. 2008-11
Rev. Proc. 2008-11
SECTION 1. PURPOSE
This revenue procedure prescribes the salvage discount factors for 2007. These factors must be used to compute discounted estimated salvage recoverable under § 832 of the Internal Revenue Code.
SEC. 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 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.
Pursuant to § 832(b), the amount of estimated salvage is determined on a discounted basis in accordance with procedures established by the Secretary.
SEC. 3. SCOPE
This revenue procedure applies to any taxpayer that is required to discount estimated salvage recoverable under § 832.
SEC. 4. APPLICATION
.01 The following tables present separately for each line of business the discount factors under § 832 for 2007. All the discount factors presented in this section were determined using the applicable interest rate under § 846(c) for 2007, which is 3.97 percent, and by assuming all estimated salvage is recovered 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. Rev. Proc. 2002-74, section 3.03, 2002-2 C.B. 980, provides that an insurance company that elects to use the composite method of Notice 88-100 must use the same method to compute discounted estimated salvage recoverable. Accordingly, the tables separately provide discount factors for taxpayers who elect to use the composite method of section V of Notice 88-100.
.02 These tables must be used by taxpayers irrespective of whether they elected to discount unpaid losses using their own experience under § 846(e).
.03 Tables.
| 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 98.0722 percent to discount salvage recoverable with respect to losses incurred in this line of business in the 2007 accident year as of the end of the 2007 and later taxable years. | |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount all salvage recoverable in this line of business as of the end of the 2007 taxable year. |
| Auto Physical Damage | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 97.2919 |
| 2008 | 96.1998 |
| 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 2007 accident year. | |
| 2009 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2009 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Commercial Auto/Truck Liability/Medical | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 92.5072 |
| 2008 | 92.4531 |
| 2009 | 92.7905 |
| 2010 | 93.1328 |
| 2011 | 93.8564 |
| 2012 | 93.6497 |
| 2013 | 92.1165 |
| 2014 | 93.0132 |
| 2015 | 96.3177 |
| 2016 | 98.0722 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Composite | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 92.5224 |
| 2008 | 92.2753 |
| 2009 | 92.1017 |
| 2010 | 91.9308 |
| 2011 | 91.3215 |
| 2012 | 90.4149 |
| 2013 | 91.2470 |
| 2014 | 92.5673 |
| 2015 | 94.5527 |
| 2016 | 96.3399 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 95.5806 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Fidelity/Surety | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 93.8272 |
| 2008 | 96.1998 |
| 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 2007 accident year. | |
| 2009 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2009 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Financial Guaranty/Mortgage Guaranty | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 94.8523 |
| 2008 | 96.1998 |
| 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 2007 accident year. | |
| 2009 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2009 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| International (Composite) | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 92.5224 |
| 2008 | 92.2753 |
| 2009 | 92.1017 |
| 2010 | 91.9308 |
| 2011 | 91.3215 |
| 2012 | 90.4149 |
| 2013 | 91.2470 |
| 2014 | 92.5673 |
| 2015 | 94.5527 |
| 2016 | 96.3399 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 95.5806 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Medical Malpractice — Claims-Made | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 92.8129 |
| 2008 | 93.8690 |
| 2009 | 92.3083 |
| 2010 | 92.9226 |
| 2011 | 92.2409 |
| 2012 | 87.9349 |
| 2013 | 84.6380 |
| 2014 | 90.4891 |
| 2015 | 96.5200 |
| 2016 | 98.0722 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Medical Malpractice — Occurrence | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 85.8039 |
| 2008 | 90.1315 |
| 2009 | 92.4448 |
| 2010 | 84.5882 |
| 2011 | 94.8975 |
| 2012 | 91.5995 |
| 2013 | 93.1599 |
| 2014 | 95.9622 |
| 2015 | 97.1608 |
| 2016 | 98.0722 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Miscellaneous Casualty | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 96.6559 |
| 2008 | 96.1998 |
| 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 2007 accident year. | |
| 2009 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2009 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Multiple Peril Lines (Homeowners/Farmowners, Commercial Multiple Peril, and Special Liability (Ocean Marine, Aircraft (All Perils), Boiler and Machinery)) | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 93.1480 |
| 2008 | 92.5520 |
| 2009 | 92.4746 |
| 2010 | 92.4125 |
| 2011 | 91.6181 |
| 2012 | 90.0772 |
| 2013 | 91.2078 |
| 2014 | 93.5843 |
| 2015 | 94.9567 |
| 2016 | 96.6862 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0719 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Other (Including Credit) | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 95.7364 |
| 2008 | 96.1998 |
| 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 2007 accident year. | |
| 2009 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2009 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Other Liability — Claims-Made | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 88.6489 |
| 2008 | 89.7449 |
| 2009 | 87.8992 |
| 2010 | 91.0630 |
| 2011 | 92.5154 |
| 2012 | 94.3565 |
| 2013 | 93.3084 |
| 2014 | 91.9440 |
| 2015 | 97.4177 |
| 2016 | 98.0722 |
| 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 2007 accident year. | |
| 2019 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 96.8697 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Other Liability — Occurrence | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 87.3760 |
| 2008 | 88.3943 |
| 2009 | 90.6775 |
| 2010 | 91.4222 |
| 2011 | 90.8722 |
| 2012 | 90.9863 |
| 2013 | 90.4663 |
| 2014 | 93.1478 |
| 2015 | 95.8515 |
| 2016 | 97.6241 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Private Passenger Auto Liability/Medical | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 94.6456 |
| 2008 | 94.6698 |
| 2009 | 94.4266 |
| 2010 | 93.5793 |
| 2011 | 93.0072 |
| 2012 | 92.2508 |
| 2013 | 93.1304 |
| 2014 | 94.6575 |
| 2015 | 94.7279 |
| 2016 | 96.4851 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0708 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Products Liability — Claims-Made | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 89.1458 |
| 2008 | 52.2690 |
| 2009 | 54.6584 |
| 2010 | 90.8903 |
| 2011 | 80.5163 |
| 2012 | 91.5977 |
| 2013 | 60.2981 |
| 2014 | 90.6932 |
| 2015 | 91.8054 |
| 2016 | 92.9177 |
| 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 2007 accident year. | |
| 2017 | 94.6739 |
| 2018 | 96.4396 |
| 2019 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 94.6739 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Products Liability — Occurrence | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 87.8817 |
| 2008 | 89.9255 |
| 2009 | 91.7722 |
| 2010 | 92.5755 |
| 2011 | 93.0145 |
| 2012 | 90.6124 |
| 2013 | 91.2345 |
| 2014 | 94.1309 |
| 2015 | 94.3955 |
| 2016 | 96.2156 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 94.6056 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Reinsurance — Nonproportional Assumed Property | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 91.2766 |
| 2008 | 92.8906 |
| 2009 | 95.7836 |
| 2010 | 80.5177 |
| 2011 | 90.0569 |
| 2012 | 81.8877 |
| 2013 | 52.3517 |
| 2014 | 92.9805 |
| 2015 | 73.8412 |
| 2016 | 88.3425 |
| 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 2007 accident year. | |
| 2017 | 90.0606 |
| 2018 | 91.8464 |
| 2019 | 93.7215 |
| 2020 | 95.7382 |
| 2021 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 90.0606 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Reinsurance — Nonproportional Assumed Liability | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 87.0242 |
| 2008 | 90.2399 |
| 2009 | 91.6689 |
| 2010 | 88.8580 |
| 2011 | 90.8909 |
| 2012 | 91.7421 |
| 2013 | 91.6386 |
| 2014 | 93.3665 |
| 2015 | 95.2650 |
| 2016 | 96.9798 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 93.1607 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Reinsurance — Nonproportional Assumed Financial Lines | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 87.4122 |
| 2008 | 86.1745 |
| 2009 | 90.1030 |
| 2010 | 78.9216 |
| 2011 | 90.4446 |
| 2012 | 80.6766 |
| 2013 | 90.6123 |
| 2014 | 91.0121 |
| 2015 | 97.5684 |
| 2016 | 98.0722 |
| 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 2007 accident year. | |
| 2017 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary and Theft) | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 94.9917 |
| 2008 | 96.1998 |
| 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 2007 accident year. | |
| 2009 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 98.0722 percent to discount salvage recoverable as of the end of the 2009 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
| Workers’ Compensation | |
|---|---|
| Tax Year | Discount Factors (%) |
| 2007 | 88.6073 |
| 2008 | 90.6085 |
| 2009 | 91.3932 |
| 2010 | 91.3110 |
| 2011 | 89.8407 |
| 2012 | 88.4546 |
| 2013 | 89.0394 |
| 2014 | 88.7616 |
| 2015 | 90.9000 |
| 2016 | 92.6321 |
| 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 2007 accident year. | |
| 2017 | 94.4075 |
| 2018 | 96.2249 |
| 2019 and later years | 98.0722 |
| Taxpayers that use the composite method of Notice 88-100 should use 95.3569 percent to discount salvage recoverable as of the end of the 2017 taxable year with respect to losses incurred in this line of business in 2007 and prior years. |
DRAFTING INFORMATION
The principal author of this revenue procedure is Katherine A. Hossofsky of the Office of Associate Chief Counsel (Financial Institutions & Products). For further information regarding this revenue procedure, contact Ms. Hossofsky at (202) 622-8435 (not a toll-free call).
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