On July 11, 2019, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued comprehensive proposed regulations on passive foreign investment companies (PFICs) that include guidance on the...more
On its current course, this year could be both the best and the worst of times for insurance. The US economy continues to enjoy steady growth, stock indices continue to reach new highs and tax reform in the US allows both...more
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
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
For decades American companies have used so-called “corporate inversions” to lower their tax burdens on foreign-earned income. Typically, the American company is acquired by a foreign company located in a tax-favorable...more