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IRS Issues Proposed Passive Foreign Investment Company (PFIC) Regulations for Non-U.S. Insurance Companies
24 April 2015
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New proposed regulations confirm that assets held by a non-U.S. insurance company to meet obligations under its insurance contracts are nonpassive for PFIC purposes, but do not provide specific guidelines for determining the portion of assets held for this purpose.
Under the proposed regulations, to qualify for the exception for active insurance businesses, a non-U.S. insurance company’s own officers and employees must carry on substantial business activities.
The IRS has solicited comments on methods for determining whether assets are held to meet obligations under insurance contracts.
Peter F.G. Schuur
Seth L. Rosen
Peter A. Furci
Gary M. Friedman
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