IRS Issues Revenue Procedure Providing Domestic Asset, Liability Percentages, Investment Yields for Foreign Insurance Companies

The IRS issued a revenue procedure providing the domestic asset/liability percentages and domestic investment yields that foreign life insurance companies and foreign property and casualty insurance companies must use to compute their minimum effectively connected net investment income under I.R.C. §842(b) for taxable years beginning after Dec. 31, 2024. For 2025, foreign life insurance companies must apply a domestic asset/liability percentage of 128.2 percent and a domestic investment yield of 2.1 percent, while foreign property and casualty insurance companies must apply 202.4 percent and 2.2 percent, respectively. The guidance also provides instructions for computing estimated tax and installment payments of ...