To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules.

[Congressional Bills 119th Congress] [From the U.S. Government Publishing Office] [H.R. 2567 Introduced in House (IH)] <DOC> 119th CONGRESS 1st Session H. R. 2567 To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. _______________________________________________________________________ IN THE HOUSE OF REPRESENTATIVES April 1, 2025 Ms. Moore of Wisconsin (for herself and Mr. Smith of Nebraska) introduced the following bill; which was referred to the Committee on Ways and Means _______________________________________________________________________ A BILL To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules. Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. TREATMENT OF FINANCIAL GUARANTY INSURANCE COMPANIES AS QUALIFYING INSURANCE CORPORATIONS UNDER PASSIVE FOREIGN INVESTMENT COMPANY RULES. (a) In General.--Section 1297(f)(3) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: ``(C) Special rules for financial guaranty insurance companies.-- ``(i) In general.--Notwithstanding subparagraphs (A)(ii) and (B), the applicable insurance liabilities of a financial guaranty insurance company shall include its unearned premium reserves if-- ``(I) such company is prohibited under generally accepted accounting principles from reporting on its applicable financial statements reserves for losses and loss adjustment expenses with respect to a financial guaranty insurance or reinsurance contract except to the extent that losses and loss adjustment expenses are expected to exceed the unearned premium reserves on the con