This revenue procedure provides simplified procedures for an insurance company to obtain automatic consent of the Commissioner of Internal Revenue to change its methods of accounting for discounting unpaid losses and expenses unpaid, estimated salvage recoverable, and unearned premiums attributable to title insurance, as applicable, to comply with § 846, as amended by section 13523 of the Tax Cuts and Jobs Act, Public Law 115-97 (131 Stat. 2054, 2152) for taxable years beginning after December 31, 2017, and ending on or before December 31, 2019.

26 CFR 601.204: Changes in accounting periods and in methods of accounting.

(Also: Part I, Sections 446, 846.)

The revenue procedure prescribes revised discount factors for the 2018 accident year, as well as discount factors for the 2019 accident year. These discount factors will be used to compute discounted unpaid losses under § 846 of the Internal Revenue Code and discounted estimated salvage recoverable under § 832. The discount factors prescribed in the revenue procedure are determined under § 846, as amended by section 13523 of the Tax Cuts and Jobs Act, Public Law 115-97 (131 Stat. 2054, 2152), and final regulations under § 846 published in the Federal Register (84 FR 27947) on June 17, 2019.

This revenue procedure grants an extension of time to eligible BBA partnerships to file a superseding Form 1065, U.S. Return of Partnership Income, and furnish a corresponding Schedule K-1 (Form 1065), Partner’s Share of Income, Deductions, Credits, etc., to each of its partners.

These final regulations prescribe the manner in which an organization operating under IRC section 501(c)(4) must submit the notification required by IRC section 506.

These final regulations provide rules that improve the operation of an existing safe harbor rule that is used for determining whether partnership allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners’ interests in the partnership.

26 CFR 1.704-1: Allocation of Creditable Foreign Taxes