Description: A summary and analysis of REG-103163-18, the proposed regulations providing guidance for property-casualty loss reserve discounting (LRD) under IRC Section 846.

Description: On June 17, 2019, the Internal Revenue Service published Final Regulations implementing changes to loss reserve discounting under section 846 of the Internal Revenue Code made by the Tax Cuts and Jobs Act. This note addresses changes made in the Final Regulations, particularly modification of rules for determining the interest rate used for discounting, in response to comments from taxpayers on the proposed regulations.

Description: This article focuses on the TCJA’s changes to the provisions for net operating losses (“NOLs”) and highlights some of the challenges surrounding the NOL provisions that insurance companies may face when making business decisions around reinsurance agreements.