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HR 2567119th CongressIntroduced
To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules.
Introduced: Oct 28, 2025
Standard Summary
Comprehensive overview in 1-2 paragraphs
Amends Internal Revenue Code to provide special rules for financial guaranty insurance companies under passive foreign investment company (PFIC) rules.
Key Points
- 1Provides special PFIC treatment for financial guaranty insurers
- 2Includes unearned premium reserves in insurance liabilities
- 3Sets specific exposure ratio requirements
- 4Applies to companies with certain bond exposure ratios
- 5Includes reporting requirements and effective dates
- 6Provides grace period for prior years
Impact Areas
International tax lawInsurance industry regulationFinancial services taxationForeign investment rules
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