Offshore Reinsurance Tax Fairness Act
Official title: A bill to amend the Internal Revenue Code of 1986 to restrict the insurance business exception to passive foreign investment company rules.
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Read twice and referred to the Committee on Finance. (Sponsor introductory remarks on measure: CR S4650; text of measure as introduced: CR S4650-4652)
Offshore Reinsurance Tax Fairness Act
Amends the Internal Revenue Code to define "qualifying insurance corporation," for purposes of the insurance business exception to passive foreign investment company rules, as a foreign corporation: (1) that would be subject to U.S. taxation if it were a domestic corporation, and (2) the applicable insurance liabilities of which constitute more than 25% of its total assets. Allows an alternative facts and circumstances test for insurance corporations whose applicable insurance liabilities are not at least 25% of total assets if such percentage is at least 10% and the corporation is predominantly engaged in an insurance business.
- Introduced in Senate Formatted Text PDF Formatted XML
Cite this page
U.S. Congress. (2026). S. 1687: Offshore Reinsurance Tax Fairness Act. 114th Congress. Open America. https://openamerica.io/bill/114-S-1687/
"S. 1687: Offshore Reinsurance Tax Fairness Act." 114th Congress, 2026, Open America, https://openamerica.io/bill/114-S-1687/.
S. 1687, 114th Cong. (2026), https://openamerica.io/bill/114-S-1687/.
[S. 1687: Offshore Reinsurance Tax Fairness Act](https://openamerica.io/bill/114-S-1687/)