- 9 - $125 million at the end of 1987. But for section 846, the losses incurred deduction attributable to unpaid losses would have been $25 million (i.e., $125 million - $100 million). If pursuant to section 846 the $125 million of reserves at the end of 1987 were discounted to $110 million, the P&C insurer's losses incurred deduction would have been reduced from $25 million to $10 million (i.e., $110 million - $100 million). To address this problem, Congress included a transition rule in TRA '86. The transition rule provided that, for purposes of computing the losses incurred deduction at yearend 1987, 1986 reserves also would be discounted. TRA '86 sec. 1023(e)(2), 100 Stat. 2404. As a result of this transition rule, discounted 1987 reserves were compared with discounted 1986 reserves in computing the losses incurred deduction for the 1987 taxable year. B. The Application of Section 481 Even with the transition rule described above, P&C insurance companies remained subject to adverse tax consequences due to the application of section 481. When a taxpayer changes its method of accounting, section 481 generally requires that the taxpayer make adjustments to prevent amounts from being duplicated in or omitted from its taxable income. Compliance with the requirement that P&C insurers change the basis for computing their losses incurred deductions from an undiscounted to a discounted methodology constituted a change in accounting method. Thus, section 481 would have required P&C insurers to recognize asPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011