SECTION 1. PURPOSE

This revenue procedure provides procedures for an insurance company changing its basis of computing reserves pursuant to § 807(f) of the Internal Revenue Code (Code), as amended by section 13513 of the Tax Cuts and Jobs Act, Pub. L. No. 115–97 (December 22, 2017) (TCJA). This revenue procedure modifies Rev. Proc. 2018–31, 2018–22 I.R.B. 637, to provide procedures under § 446 and § 1.446–1(e) of the Income Tax Regulations for an insurance company to obtain automatic consent of the Commissioner of Internal Revenue (Commissioner) to change its method of accounting to comply with § 807(f). This revenue procedure also modifies Rev. Rul. 94–74, 1994–2 C.B. 157, and Rev. Rul. 2002–6, 2002–1 C.B. 460, to the extent the holdings are inconsistent with the general rules for changing a method of accounting under § 446(e) and § 1.446–1(e).

In addition, this revenue procedure provides guidance on (i) accounting for an adjustment that arose under § 807(f) prior to its amendment by the TCJA and (ii)

how a change in basis of computing life insurance reserves must be taken into account for purposes of computing amounts under the transition relief rule of section 13517 of the TCJA.