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Neal bill debated before House subcommittee
14 July 2010
The US House Ways and Means Select Revenue Measures Subcommittee has held a hearing on the taxation of reinsurance between affiliated entities.
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The US House Ways and Means Select Revenue Measures Subcommittee has held a hearing on the taxation of reinsurance between affiliated entities.
The hearing focused on the issue of reinsurance between affiliated entities and recent proposals that would impact certain reinsurance premiums paid to related foreign entities.
The US 2011 budget cites concerns that the tax advantages from related party foreign reinsurance creates an incentive to reinsure more than would occur between unrelated parties acting at arm’s length.
As such, the budget contains a provision to deny a deduction for reinsurance premiums paid to related foreign reinsurance companies if the related foreign entity was not subject to US tax with respect to those premiums and the amount of the premiums (less ceding commissions) exceeds 50% of the total direct insurance premiums received by the US company and its US affiliates for a line of business, said the...
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