Bill > HR5746

This bill amends the Internal Revenue Code of 1986 to provide special rules for determining whether financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company (PFIC) rules. The key provisions are: 1. Allows financial guaranty insurance companies to include their unearned premium reserves as part of their "applicable insurance liabilities" for purposes of the PFIC rules, if certain conditions are met (such as prohibiting the company from reporting loss reserves except to the extent they exceed the unearned premium reserves, and the company having a financial guaranty exposure of at least 15-to-1). 2. Defines a "financial guaranty insurance company" as an insurance company whose sole business is writing or reinsuring financial guaranty insurance. 3. Requires certain financial information related to the PFIC determination to be separately reported on the company's applicable financial statement. 4. Gives the Secretary of the Treasury authority to require U.S. persons owning interests in certain non-publicly traded foreign corporations to report information about whether the corporation is a PFIC. The amendments generally take effect as if included in prior legislation, except the reporting requirements apply to reports made after the date of enactment.

Budget and Finance

https://www.congress.gov/bill/116th-congress/house-bill/5746/all-info