US final and proposed regulations on passive foreign investment companies have both favorable and unfavorable implications for insurance companies
Executive summary
Final regulations (T.D. 9936; Final Regulations) and proposed regulations (REG-111950-20; 2020 Proposed Regulations) under the passive foreign investment company (PFIC) rules include provisions that significantly affect insurance companies. Those provisions include:
- Detailed guidance on the identification of applicable insurance liabilities, computation of the ratio of applicable i…