SECTION 2. CHANGES

.01 DOMESTIC ASSET/LIABILITY PERCENTAGES FOR 1998. The Secretary determines the domestic asset/liability percentage separately for life insurance companies and property and liability insurance companies. For the first taxable year beginning after December 31, 1997, the relevant domestic asset/liability percentages are:

117.4 percent for foreign life insurance companies, and

1999–31 I.R.B. 221 August 2, 1999

techniques to collect data from the tax returns of domestic insurance companies. The sampling technique considered was the same used to select insurance company tax returns in IRS Statistics Division’s Publication 16 (section 3 thereof). Although the Service solicited comments in Rev. Proc. 98–31 addressing the use of this statistical sampling technique to calculate the section 842(b) percentages, none were received. The Service has assessed the accuracy of using sampling techniques and found that percentages based on statistical sampling techniques would be reliable. However, the cost of obtaining population estimates of the applicable percentages does not warrant reliance on a sampling technique. Thus, the percentages for the 1998 tax year are based on the population of tax returns.