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Passive Foreign Investment Company Insurance Industry

Eversheds Sutherland (US) LLP

Long-awaited passive foreign investment company proposed regulations – focus on insurance

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

Eversheds Sutherland (US) LLP

Insurance Topics We Will Be Watching in 2018

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

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

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

Carlton Fields

Proposed Anti-Inversion Regulations Would Affect Foreign Insurers

Carlton Fields on

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

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