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New PFIC regs active conduct test excludes ILS funds & structures

8th December 2020

A new set of guidance on the treatment of passive foreign investment companies (PFICs) published at the end of last week by the U.S. Internal Revenue Service and Department of the Treasury has been modified so that the active conduct test excludes insurance-linked securities (ILS) funds, as well as other ILS and reinsurance securitization structures.

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