Bill · H.R. 2567· House(119-HR-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.
- Introduced
- 4/1/2025
- Last activity
- 4/1/2025 — Referred to the House Committee on Ways and Means.
- Sponsored by
- Gwen Moore
- Cosponsors
- - 1 - 2
- Introduced
- In Committee
What this bill would do
This bill proposes amendments to the Internal Revenue Code of 1986 regarding financial guaranty insurance companies. It seeks to provide special rules for determining if these companies qualify as insurance corporations under passive foreign investment company rules. The legislation introduces specific requirements for insurance liabilities, including unearned premium reserves, and defines financial guaranty exposure and state or local bond exposure. It also grants the Secretary authority to determine if certain guidelines have been met. Additionally, the bill includes new reporting requirements for certain United States persons and non-publicly traded foreign corporations. These changes are intended to apply to taxable years beginning after December 31, 2024.
Yes
Would business owners be better off under this?+2
The bill provides clearer tax status definitions for financial guaranty insurance companies.
The opposite
Would people with substantial wealth be better off under this?-2
The bill imposes new reporting obligations for United States persons owning interests in specified foreign corporations.
Who it would affect, and how
Potential Positive Impacts for People
-
Clarification of Tax Status: The bill provides specific rules for determining if a financial guaranty insurance company is a qualifying insurance corporation (Section 1, subsection a). This provides clearer definitions for companies meeting specific financial and exposure criteria.
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Simplified Reporting for Certain Amounts: The bill allows certain amounts to be treated as reported on an applicable financial statement if they are separately reported or determined (Section 1, subsection b). This could provide a clearer framework for how financial data is presented for tax purposes.
Potential Negative Impacts for People
-
Increased Reporting Burdens: The Secretary is granted authority to require United States persons who own interests in specified non-publicly traded foreign corporations to report specific information (Section 1, subsection b). This creates a new reporting obligation for these individuals.
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Regulatory Compliance Requirements: Financial guaranty insurance companies must meet specific criteria, such as specific exposure ratios and limits set by the Financial Guaranty Insurance Guideline, to qualify under these special rules (Section 1, subsection a). Failure to meet these strict criteria or reporting requirements could impact their tax treatment.
Groups and Interests Ranking
Every group the model scored this bill for, from -10 to +10. Hover a score for the reason it gave.
- Demographic And Interest Groups
- Good For Business Owners+2Good For High Net Worth Individuals-2
- 1/6/2026
- 2 Cosponsors added.
- 4/1/2025
- Referred to the House Committee on Ways and Means.
- 1 Cosponsor added.
- Introduced in House
One bill Congress.gov lists as related to this one — companions in the other chamber, earlier versions, and bills this one absorbed or was folded into.
Max MillerRepublican · Ohio
Adrian SmithRepublican · Nebraska
Terri SewellDemocrat · Alabama