Page:United States Statutes at Large Volume 100 Part 3.djvu/588

 100 STAT. 2396

PUBLIC LAW 99-514—OCT. 22, 1986 under the 2nd sentence of such paragraph by substituting '100 percent' for '80 percent' each place it appears in such subparagraph (B), and subparagraph (C) of paragraph (4) shall be applied by not taking such amounts into account. "(B) SPECIAL TREATMENT OF PREMIUMS ATTRIBUTABLE TO

INSURING CERTAIN SECURITIES.—In the case of premiums attributable to insurance against default in the payment of principal or interest on securities described in section 165(g)(2)(C) with maturities of more than 5 years— "(i) subparagraph (B) of paragraph (4) shall be applied by substituting '90 percent' for '80 percent' each place it appears, and "(ii) subparagraph (C) of paragraph (4) shall be applied by substituting ' 1 % percent' for 'SVa percent'. "(C) TERMINATION AS NONLIFE INSURANCE COMPANY.—

Except as provided in section 381(c)(22) (relating to carryovers in certain corporate readjustments), if, for any taxable year beginning before January 1, 1993, the taxpayer ceases to be an insurance company taxable under this part, the aggregate adjustments which would be made under paragraph (4)(C) for such taxable year and subsequent taxable years but for such cessation shall be made for the taxable year preceding such cessation year. "(8) SPECIAL RULES FOR APPLYING PARAGRAPH (4) TO TITLE INSURANCE PREMIUMS.—

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"(A) IN GENERAL.—In the case of premiums attributable to title insurance— "(i) subparagraph (B) of paragraph (4) shall be applied by substituting 'the discounted unearned premiums' for '80 percent of the unearned premiums' each place it appears, and "(ii) subparagraph (C) of paragraph (4) shall not apply. "(B) METHOD OF DISCOUNTING.—For purposes of subpara-

graph (A), the amount of the discounted unearned premiums as of the end of any taxable year shall be the present value of such premiums (as of such time and separately with respect to premiums received in each calendar year) determined by using— "(i) the amount of the undiscounted unearned premiums at such time, "(ii) the applicable interest rate, and "(iii) the applicable statutory premium recognition pattern. "(C) DETERMINATION OF APPLICABLE FACTORS.—In determining the amount of the discounted unearned premiums as of the end of any taxable year— "(i) UNDISCOUNTED UNEARNED PREMIUMS.—The term 'undiscounted unearned premiums' means the unearned premiums shown in the yearly statement filed by the taxpayer for the year ending with or within such taxable year. "(ii) APPLICABLE INTEREST RATE.—The term 'applicable interest rate' means the annual rate determined under 846(c)(2) for the calendar year in which the premiums are received. ,„,.. ^ ^ „. -

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