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This bill amends the Internal Revenue Code to provide special tax treatment for financial guaranty insurance companies under the passive foreign investment company (PFIC) rules. Specifically, it allows these companies to include unearned premium reserves in their insurance liabilities if they meet certain accounting and exposure thresholds, and it requires U.S. persons who own interests in such foreign corporations to report specified information to the IRS. The bill applies to taxable years beginning after December 31, 2024, and includes a grace period provision for companies that would have qualified under prior rules.
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