applicable interest rate
(8) Special rules for applying paragraph (4) to title insurance premiums (A) In general In the case of premiums attributable to title insurance— (i) subparagraph (B) of paragraph (4) shall be applied by substituting “the discounted unearned premiums” for “80 percent of the unearned premiums” each place it appears, and (ii) subparagraph (C) of paragraph (4) shall not apply. (B) Method of discounting For purposes of subparagraph (A), the amount of the discounted unearned premiums as of the end of any taxable year shall be the present value of such premiums (as of such time and separately with respect to premiums received in each calendar year) determined by using— (i) the amount of the undiscounted unearned premiums at such time, (ii) the applicable interest rate, and (iii) the applicable statutory premium recognition pattern. (C) Determination of applicable factors In determining the amount of the discounted unearned premiums as of the end of any taxable year— (i) Undiscounted unearned premiums The term “undiscounted unearned premiums” means the unearned premiums shown in the yearly statement filed by the taxpayer for the year ending with or within such taxable year. (ii) Applicable interest rate The term “applicable interest rate” means the annual rate determined under 846(c)(2) for the calendar year in which the premiums are received. (iii) Applicable statutory premium recognition pattern The term “applicable statutory premium recognition pattern” means the statutory premium recognition pattern— (I) which is in effect for the calendar year in which the premiums are received, and (II) which is based on the statutory premium recognition pattern which applies to premiums received by the taxpayer in such calendar year. For purposes of the preceding sentence, premiums received during any calendar year shall be treated as received in the middle of such year.
26 USC § 832(b)(8)
None identified, default scope is assumed to be the parent (part II) of this section.