Executive summaryFinal 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 insurance liabilities to total assets, identification of the applicable financial statement and adjustments required to amounts reported on the applicable financial statementModified standards for determining when a foreign insurance company is in “runoff-related” or “ratings-related” circumstancesRe-proposed guidance on the active conduct test, which would favorably permit active conduct to be demonstrated by meeting either...