SECTION 1. PURPOSE

This revenue procedure provides the domestic asset/liability percentages and domestic investment yields needed by foreign life insurance companies and foreign property and liability insurance companies to compute their minimum effectively connected net investment income under section 842(b) of the Internal Revenue Code for taxable years beginning after December 31, 2021. Instructions are provided for computing foreign insurance

1 While the Background section of Notice 2014-21 describes both virtual currency and convertible virtual currency, Section 3 of Notice 2014-21 explains that the term “virtual currency” as used in section 4 of the Notice refers only to convertible virtual currency.

2 See U.S. Department of the Treasury, Crypto-Assets: Implications for Consumers, Investors and Businesses at 1 and 20 (September 2022), available at https://home.treasury.gov/system/ files/136/CryptoAsset_EO5.pdf . See also OECD, Taxing Virtual Currencies: An Overview of Tax Treatments and Emerging Tax Policy Issues, at 20 (Oct. 12, 2020), available at https://www. oecd.org/tax/tax-policy/taxing-virtual-currencies-an-overview-of-tax-treatments-and-emerging-tax-policy-issues.pdf .

Bulletin No. 2023–19 837 May 8, 2023

26 CFR 601.601: Rules and Regulations (Also Part 1, §§ 25, 143, 6a.103A-1(b)(4), 6a.103A- 2(f)(5)).