Ezel / IRS Rulings / 200952057

CCA 200952057: Qualified long-term care contracts use accident and health discount factors

Number
200952057
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definition; Discounted Unpaid Losses Defined
Topics
Life insurance products Other topics
Code sections
§ 7702B, § 846
Ruling dated
October 13, 2009
Publicly released
December 25, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice addresses which discount factors should be used for qualified long-term care insurance contracts. The advice agrees that the contracts should be discounted using accident and health discount factors because IRC section 7702B(a)(1) treats a qualified long-term care insurance contract as an accident and health insurance contract.

Ruling snapshot

  • Question: Should qualified long-term care insurance contracts be discounted using accident and health discount factors?
  • Outcome: Advice given
  • Key authorities: IRC §§ 7702B(a)(1) and 846

Full text (IRS public release)

ID: CCA-10131125-09 Number: 200952057
Release Date: 12/24/2009
Office: ----------------
UILC: 7702B.02-00, 846.00-00

From: ------------------
Sent: October 13, 2009
To: --------------------
Cc:
Subject: Long Term Care Insurance

-----, I have never been asked this question. I do agree with your suggested response that it should be
discounted using the A&H discount factors because section 7702B (a)(1) says that a qualified long term
care insurance contract shall be treated as an accident and health insurance contract. -----

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