Insights & Publications
Diversity & Inclusion
© 2021 Debevoise & Plimpton LLP
Back to Top
Final and Proposed Regulations on PFIC Rules Provide Helpful Clarifications for Insurers
14 December 2020
View Debevoise In Depth
The Treasury and the IRS have released Final and Proposed Regulations relating to passive foreign investment companies (“PFICs”), including the rules granting an exception for active insurance companies.
The Proposed Regulations give foreign insurance companies more flexibility in establishing that they are sufficiently active to avoid PFIC status, but the rules may be difficult to satisfy for foreign insurance companies that rely to a significant degree on outsourcing.
The Final Regulations also improve rules for groups with U.S. insurance and other subsidiaries, as compared with previously proposed regulations.
Gary M. Friedman
Peter A. Furci
Peter F.G. Schuur
View More Authors
UK Modern Slavery Act Transparency Statement
Debevoise Login (2)
Debevoise Women's Review