Executive summaryIn proposed regulations (REG-118250-20) (the Proposed Regulations) issued 24 January 2022, the United States (US) Department of Treasury (Treasury) and the Internal Revenue Service (IRS) address, among other items, the subpart F regime on related person insurance income (RPII).1 The Proposed Regulations would expand the scope of relationships giving rise to RPII, repropose an anti-abuse rule addressing certain cross-insurance arrangements, and provide for aggregate treatment of pass-through entities to characterize income as RPII. This Tax Alert focuses on the effects of the Proposed Regulations on the insurance industry.The Proposed Regulations generally would apply to tax years of foreign corporations beginning on...