IRS Sets Hearing on Hedge Fund Reinsurer Rules

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Aug. 18 — The IRS will be hearing from insurance groups over proposed regulations aimed at preventing hedge funds from avoiding taxes by establishing purported offshore insurance companies that can be used to claim tax reductions and deferrals.

Insurance industry groups have been pushing the IRS to revise proposed rules (REG-108214-15) that would treat companies with significant income from investments as passive foreign investment companies subject to a harsher tax regime. The Reinsurance Association of America and the Association of Bermuda Insurers and Reinsurers are among groups that requested the hearing (79 DTR G-1, 4/24/15).

The two groups also asked for provisions that define “active conduct” and prevent companies in a group from sharing employees.