Foreign Insurance Companies Archives

IRS roundup: April 13 – April 17, 2026

by Kai M. Fenty | Apr 24, 2026 | IRS Guidance, Significant Court Decision, Trial Courts

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for April 13, 2026 – April 17, 2026.

April 13, 2026: The IRS issued Notice 2026-26, providing updated monthly interest rates for pension funding calculations, including the corporate bond yield curve, spot segment rates under § 417(e)(3), and 24-month average segment rates under § 430(h)(2). The notice also provides the 30-year Treasury rate for March 2026 (4.85%) and related weighted average rates used in determining minimum funding requirements.

April 13, 2026: The IRS issued Revenue Procedure 2026-19, providing updated domestic asset/liability percentages and investment yields used by foreign insurance companies to compute minimum effectively connected net investment income under § 842(b) for 2025. The guidance sets the domestic asset/liability percentages at 128.2% for foreign life insurers and 202.4% for foreign property and casualty insurers, with corresponding domestic investment yields of 2.1% and 2.2%, respectively.

The revenue procedure also provides instructions for calculating estimated tax and installment payments, requiring taxpayers to use these updated percentages and yields when determining minimum effectively connected net investment income and reflects data derived from 2023 tax return information.

April 13, 2026: The IRS issued Revenue Ruling 2026-8, providing updated Standard Industry Fare Level rates and the terminal charge for valuing noncommercial flights on employer-provided aircraft under § 61 and Treasury Regulation § 1.61-21(g). Starting January 1 through June 30, 2026, the ruling sets the terminal charge at $54.48 and establishes mileage rates of $0.2980 (up to 500 miles), $0.2272 (501 to 1,500 miles), and $0.2184 (more than 1,500 miles), which are used to calculate the taxable value of this fringe benefit.

April 16, 2026: The IRS issued Revenue Ruling 2026-9, providing monthly applicable federal rates (AFRs) for May 2026, including short-, mid-, and long-term rates under § 1274, as well as adjusted AFRs, § 382 rates, and low-income housing credit percentages. The ruling also sets the § 7520 rate at 5.00% for determining present value calculations.

The IRS also released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums, and Chief Counsel Advice)

Recent court decision

April 15, 2026: A federal district court in Texas held that the IRS exceeded its statutory authority in designating certain micro-captive insurance arrangements as “listed transactions” under § 6707A, finding that the agency failed to demonstrate that such transactions are presumptively tax-avoidant. Relying on Loper Bright, the court emphasized that it must exercise independent judgment in determining the limits of the IRS’s statutory authority, rejecting any deference to the agency’s interpretation and focusing on whether the regulations fell within the outer bounds of Congress’s delegation. The court concluded that § 6707A requires a meaningful distinction between transactions that merely have the potential for abuse and those that are more likely than not tax-avoidant and found that the administrative record did not support the heightened standard required for listed transactions. The court therefore declared Treasury [...]

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Weekly IRS Roundup May 6 – May 10, 2024

by Kevin Spencer, Evan Walters and Sama Kaseer | May 16, 2024 | IRS Guidance, Tax Reform

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 6, 2024 – May 10, 2024.

May 6, 2024: The IRS released Internal Revenue Bulletin 2024-19, which includes the following:

Revenue Ruling 2024-09, which provides the May 2024 applicable federal rates.
Notice 2024-35, which provides guidance related to certain specified required minimum distributions for certain stock bonus, pension and profit-sharing plans described in Internal Revenue Code (Code) § 401(a). The notice also announces that the IRS intends to issue related final regulations that will apply for calendar years beginning on or after January 1, 2025.
Revenue Procedure 2024-20, which provides the domestic asset and liability percentages and domestic investment yields needed by foreign life insurance companies, foreign property and liability insurance companies to compute their minimum effectively connected net investment income under Code § 842(b). The revenue procedure also provides instructions for computing foreign insurance companies’ estimated tax liabilities.
Treasury Decision 9990, which amends the definition of short-term, limited-duration insurance for purposes of exclusion from the definition of “individual health insurance coverage” under the Public Health Service Act and provides regulations regarding requirements for hospital indemnity or other fixed indemnity insurance to be considered an excepted benefit in the group and individual health insurance markets.
Revenue Procedure 2024-21, which provides issuers of qualified mortgage bonds (as defined in § 143(a)) and issuers of mortgage credit certificates (as defined in § 25(c)) with the nationwide average purchase price for residences located in the United States and the average area purchase price safe harbors for residences located in statistical areas in each state, the District of Columbia and US territories.
Announcement 2024-20, which revokes the § 501(c)(3) determination for specified organizations and stipulates that contributions made to said organizations by individual donors are no longer deductible under Code § 170(b)(1)(A).

May 6, 2024: The IRS recognized two of its teams that reached the finals for the Samuel J. Heyman Service to America Medals as part of the 2024 Public Service Recognition Week. These teams included the Paperless Processing Initiative Team for its efforts to digitize IRS correspondence and two CI special agents for spearheading an investigation that led to a $3.4 billion cryptocurrency seizure and forfeiture.

May 6, 2024: The IRS reminded one million taxpayers who did not file their 2020 tax returns that they may still be eligible for a refund if they file by the May 17, 2024, deadline. The IRS estimates that more than $1 billion in refunds remain unclaimed as a result.

May 6, 2024: The IRS provided general tips for taxpayers upon receipt of mail from the IRS. In particular, taxpayers should remember to carefully read all IRS letters, save copies for their records and timely dispute notices where applicable.

May 6, 2024: The IRS
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Weekly IRS Roundup August 26 – 30, 2019

by McDermott Will & Emery | Sep 3, 2019 | IRS Guidance, Uncategorized

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of August 26 – 30, 2019.

August 26, 2019: The IRS released a Treasury Decision in which it issued correcting amendments to TD 9866 (i.e., the global intangible low-taxed income (GILTI) and Foreign Tax Credit Regulations pertaining to IRC §951A). The correcting amendments to Treasury Regulations Section 1.951A-2 include in the second sentence of paragraph (c)(4)(iv)(A)(2)(i), removing the language “paragraph (c)(4)(ii)(A)” and adding “paragraph (c)(4)(iii)(A)” in its place, and in the third sentence, removing the language “paragraph (c)(4)(ii)(B)” and adding “paragraph (c)(4)(iii)(B)” in its place, among other changes.

August 27, 2019: The IRS released a revenue procedure in which it added Georgia to the list of countries for which the United States has an automatic exchange of deposit interest information as related to certain nonresident alien individuals. This revenue procedure supersedes Rev. Proc. 2018-36.

August 28, 2019: The IRS issued a news release and a revenue procedure in which it announced that interest rates will remain the same for the calendar quarter beginning October 1, 2019, as they were in the prior quarter. Specifically, those rates are 5% for overpayments (4% for corporations), 2.5% for the portion of a corporate overpayment exceeding $10,000, 5% for underpayments, 7% for large corporate underpayments and, for taxpayers other than corporations, the overpayment and underpayment rate is the federal short-term rate plus 3 percentage points.

August 29, 2019: The IRS released a revenue procedure in which it set forth 2018 annual percentages for Foreign Insurance Companies carrying on US business. Specifically, the domestic asset/liability percentage was set at 118.3% for foreign life insurance companies and 201.2% for foreign property and liability insurance companies. The revenue procedure also published domestic investment yields of 4.5% for foreign life insurance companies and 3.5% for foreign property and liability insurance companies. The IRS stated that a foreign insurance company must compute its estimated tax payments for its investment income for such taxable years by using the greater of its actual effectively connected net investment income or its minimum net investment income using these percentages, except that such company may continue to use the prior year’s percentages, as published in Revenue Procedure 2018-45, if the due date of an installment is less than 20 days after the current procedure is published in the Internal Revenue Bulletin.

August 30, 2019: The IRS released its weekly list of written determinations (e.g., Private Letter Rulings, Technical Advice Memorandums and Chief Counsel Advice).

Special thanks to Alex Ruff in our Chicago office for this week’s roundup.

IRS roundup: April 13 – April 17, 2026

Weekly IRS Roundup May 6 – May 10, 2024

Weekly IRS Roundup August 26 – 30, 2019

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