[Code of Federal Regulations]
[Title 26, Volume 8]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.846-0]

[Page 749]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
Determination of Tax Liability--Table of Contents
 
Sec. 1.846-0  Outline of provisions.

    The following is a list of the headings in Sec. Sec. 1.846-1 
through 1.846-4.

             Sec. 1.846-1 Application of discount factors.

    (a) In general.
    (1) Rules.
    (2) Examples.
    (3) Increase in discounted unpaid losses shown on the annual 
statement.
    (4) Increase in unpaid losses which take into account estimated 
salvage recoverable.
    (b) Applicable discount factors.
    (1) In general.
    (i) Discount factors published by the Service.
    (ii) Composite discount factors.
    (iii) Annual statement changes.
    (2) Title insurance company reserves.
    (3) Reinsurance business.
    (i) Proportional reinsurance for accident years after 1987.
    (ii) Non-proportional reinsurance.
    (A) Accident years after 1991.
    (B) Accident years 1988 through 1991.
    (iii) Reinsurance for accident years before 1988.
    (iv) 90 percent exception.
    (4) International business.
    (5) Composite discount factors.

   Sec. 1.846-2 Election by taxpayer to use its own historical loss 
                            payment pattern.

    (a) In general.
    (b) Eligible line of business.
    (1) In general.
    (2) Other published guidance.
    (3) Special rule for 1987 determination year.
    (c) Anti-abuse rule.

          Sec. 1.846-3 Fresh start and reserve strengthening.

    (a) In general.
    (b) Applicable discount factors.
    (1) Calculation of beginning balance.
    (2) Example.
    (c) Rules for determining the amount of reserve strengthening.
    (1) In general.
    (2) Accident years after 1985.
    (i) In general.
    (ii) Hypothetical unpaid loss reserve.
    (3) Accident years before 1986.
    (i) In general.
    (ii) Exceptions.
    (iii) Certain transactions deemed to be reinsurance assumed (ceded) 
in 1986.
    (d) Section 845.
    (e) Treatment of reserve strengthening.
    (f) Examples.

                      Sec. 1.846-4 Effective date.

[T.D. 8433, 57 FR 40843, Sept. 8, 1992; 57 FR 48563, Oct. 27, 1992]