The US Treasury Department and the Internal Revenue Service on Thursday issued proposed regulations relating to the tax treatment of foreign insurance companies with US insurance operations.
Under the current rules, a foreign company with US operations is subject to US tax on the portion of its income attributable to such operations.
The proposed regulations, when finalized, would provide that portfolio stock investments of a foreign insurance company are excluded from the general rule that stock is not an asset held for use in a company's business.
Under these regulations, a foreign insurance company's portfolio stock investments may be considered as assets used in the company's US business and therefore such stock investments may produce income that is subject to US tax.
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