Asset/Liability Percentages and Investment Yields for Foreign Insurance Companies Provided (Rev. Proc. 2017-44)

The IRS has provided the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Code Sec. 842(b) for tax years beginning after December 31, 2015.

For the first tax year beginning after 2015, the relevant domestic asset/liability percentages are 122.1 percent for foreign life insurance companies and 197.1 percent for foreign property and liability insurance companies.

The relevant domestic investment yields are 4.6 percent for foreign life insurance companies and 3.6 percent for foreign property and liability insurance companies.

In addition, instructions are set forth for computing foreign insurance companies’ estimated tax liabilities for tax years beginning after December 31, 2015.

Rev. Proc. 2017-44, 2017FED ¶46,333

Other References:

Code Sec. 842

CCH Reference – 2017FED ¶26,251.72

Tax Research Consultant

CCH Reference – TRC INTL: 3,400

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