The IRS has provided the domestic asset/liability percentages and domestic investment yields needed by foreign insurance companies to compute their minimum effectively connected net investment income. For the first tax year beginning after Dec. 31, 2017, the relevant domestic asset/liability percentages are 118.3% for foreign life insurance companies and 201.2% for foreign property and liability insurance companies. For the same time period, the relevant domestic investment yields are 4.5% for foreign life insurance companies and 3.5% for foreign property and liability insurance companies. (Rev Proc 2019-36)
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