This revenue procedure prescribes the loss payment patterns and discount
factors for the 2005 accident year. These factors will be used for computing
discounted unpaid losses under � 846 of the Internal Revenue Code. See Rev.
Proc. 2003-17, 2003-1 C.B. 427, for background concerning the loss payment
patterns and application of the discount factors.
This revenue procedure applies to any taxpayer that is required to discount
its unpaid losses under � 846 for a line of business using discount
factors published by the Secretary.
SEC. 3. TABLES OF DISCOUNT FACTORS
.01 The following tables present separately for each line of business
the discount factors under � 846 for accident year 2005. All the
discount factors presented in this section were determined using the applicable
interest rate under � 846(c) for 2005, which is 4.44 percent, and
by assuming all loss payments occur in the middle of the calendar year.
.02 If the groupings of individual lines of business on the annual statement
change, taxpayers must discount the unpaid losses on the affected lines of
business in accordance with the discounting patterns that would have applied
to those unpaid losses based on their classification on the 2000 annual statement. See Rev.
Proc. 2003-17, 2003-1 C.B. 427, section 2, for additional background on discounting
under section 846 and the use of the Secretary�s tables.
.03 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. The tables separately provide
discount factors for taxpayers who elect to use the composite method of section
V of Notice 88-100. See Rev. Proc. 2002-74, 2002-2 C.B.
980.
.04 Section 2.03(4) of Rev. Proc. 2003-17 requested comments as to whether
a methodology should be adopted to smooth the raw payment data and thus produce
a more stable pattern of discount factors. This issue will be addressed in
the new determination year, which is 2007. Accordingly, taxpayers may still
submit comments that should include a reference to Rev.
Proc. 2005-72 on this issue to the following address:
CC:PA:LPD:PR (Rev. Proc. 2005-72),
room 5203, Internal Revenue Service, POB 7604, Ben Franklin Station, Washington,
DC 20044. Comments may be hand delivered between the hours of 8 a.m.
and 4 p.m. to CC:PA:LPD (Rev. Proc. 2005-72),
Courier�s Desk, Internal Revenue Service, 1111 Constitution Avenue,
NW, Washington, DC 20224. Alternatively, e-mail comments to [email protected]. All
comments will be available for public inspection and copying.
.05 Tables.
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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