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Foley & Lardner LLP

U.S. PFIC Taxation Exemption to be Narrowed?

Foley & Lardner LLP on

The last 15 years have seen the advent of a new reinsurance platform, where hedge funds have sponsored non-U.S. reinsurers, who in turn invest their capital in the sponsoring hedge funds. While there are business rationales...more

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