Bill > HR2567

This bill amends the Internal Revenue Code to provide special tax treatment for financial guaranty insurance companies under the Passive Foreign Investment Company (PFIC) rules. Specifically, the bill allows these specialized insurance companies to include unearned premium reserves in their applicable insurance liabilities under certain conditions, such as being prohibited from reporting loss reserves except when expected losses exceed unearned premiums, having a financial guaranty exposure of at least 15-to-1 or state/local bond exposure of at least 9-to-1, and adhering to specific single risk limits. The bill defines a financial guaranty insurance company as one solely writing or reinsuring financial guaranty insurance and provides detailed definitions for financial guaranty and state or local bond exposure. Additionally, the bill introduces new reporting requirements for U.S. persons owning interests in certain non-publicly traded foreign corporations and creates a grace period for qualified financial guarantee insurance companies, effectively preventing them from being classified as passive foreign investment companies during a specified timeframe (from the first taxable year after December 31, 2017, to the last taxable year before January 1, 2025). The amendments will generally apply to taxable years beginning after December 31, 2024.

Budget and Finance

https://www.congress.gov/bill/119th-congress/house-bill/2567/all-info