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Hedge Funds Passive Foreign Investment Company

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

BakerHostetler

The IRS Turns Up the Heat on Hedge Fund-Backed Reinsurance

BakerHostetler on

After years of inaction, the Internal Revenue Service (IRS) is throwing up obstacles to enjoying the tax advantages of hedge fund-backed reinsurance. On April 24, 2015, the IRS issued a notice of proposed rulemaking titled...more

Locke Lord LLP

Locke Lord QuickStudy: Proposed Regulations Issued On Hedge Fund Reinsurance Transactions

Locke Lord LLP on

The Internal Revenue Service (IRS) recently issued proposed regulations addressing what constitutes the “active conduct of an insurance business” for purposes of the passive foreign investment company (PFIC) rules (the...more

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