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SECTION 3. PROCEDURES AND
Internal Revenue Bulletin 1998-4 · 2026-10-03 edition · updated 2026-10-04 · United States
REQUIREMENTS FOR MAKING THE § 646 ELECTION
.01 Required Statement. To make the election, a required statement must be attached to a Form 1041, U.S. Income Tax Return for Estates and Trusts, at the time and in the manner described in this revenue procedure. The required statement must:
(1) Identify the election as an election made under § 646;
(2) Contain the name, address, date of death, and taxpayer identification number (TIN) of the decedent;
(3) Contain the qualified revocable trust’s name, address, and TIN. If the trust does not have a TIN because the trust was reporting pursuant to § 1.671– 4(b)(2)(i)(A) of the Income Tax Regulations, the trustee must obtain a TIN unless a Form 1041 does not have to be filed under SECTION 3.03. See § 301.6109– 1(a)(2) of the Procedure and Administration Regulations;
(4) Contain the estate’s name, address, and TIN;
Reinsurance C (Financial Lines)
Discount Tax Year Factors (%)
AY+ 0 80.6765 AY+ 1 83.1043 AY+ 2 86.4423 AY+ 3 92.4514 AY+ 4 90.9915 AY+ 5 92.9165 AY+ 6 89.3489 AY+ 7 96.8614 AY+ 8 96.9777
The discount factor for AY+9 and subsequent years equals 96.9777 percent.
Special Property (Fire, Allied Lines, Inland Marine, Earthquake, Glass, Burglary and Theft)
Discount Tax Year Factors (%)
AY+ 0 92.0611 AY+ 1 94.0911 AY+ 2 96.9777
The discount factor for AY+3 and subsequent years equals 96.9777 percent.
Workers’ Compensation
Discount Tax Year Factors (%)
AY+ 0 78.0209 AY+ 1 80.4915 AY+ 2 82.4316 AY+ 3 84.0275 AY+ 4 84.1405 AY+ 5 84.3058 AY+ 6 85.5062 AY+ 7 86.2679 AY+ 8 88.7269 AY+ 9 91.3845 AY+10 94.1425 AY+11 96.9777
The discount factor for AY+12 and subsequent years equals 96.9777 percent.
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