On 25 June 2015, Senate Finance Committee Ranking Member Ron Wyden, D-Ore introduced a bill, the Offshore Reinsurance Tax Fairness Act, which would restrict the insurance business exception to the passive foreign investment company (PFIC) rules. The main purpose of the bill is to target hedge fund reinsurance companies that are taking advantage of the current law loophole, and stop the abuse of the PFIC exemption.
Under the provisions of the bill, to be considered an insurance company eligib…