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The Global Federation of Insurance Associations (GFIA) has written to the US Treasury to call for guidance to assist insurers and their investors in complying with the Passive Foreign Investment Company (PFIC) insurance exemption, as amended by the 2017 US tax reform law. |
GFIA said that such guidance would be essential in 2018, since PFIC classification for the year is irreversible. Companies need the guidance to determine whether they will be able to maintain their non-PFIC status by meeting the qualifying insurance corporation (QIC) test. It added that US shareholders will be significantly impacted by PFIC characterisation. Guidance is critical as early as possible to provide affected companies sufficient time to make structural and capital related decisions, if necessary, which may affect their QIC status. GFIA warned that, without further guidance, a non-US parented insurance group may not be able to determine if it is characterised as a PFIC for the current year, and its US shareholders would be the ones subject to US tax consequences, such as higher tax obligations and payment of estimated tax and penalties. It is important that non-US parented insurance groups can determine their QIC exemption status, so as to advise their shareholders of a possible PFIC classification. To make this assessment, insurance groups need clarification of the rules for qualifying as a QIC.
GFIA also called for guidance on the following topics: |
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Capital excellence in the capital - S... | ||
London - Negotiable |
Life Reinsurance Associate - Bermuda | ||
Bermuda - Negotiable |
Life Reinsurance Director - Bermuda | ||
Bermuda - Negotiable |
Scotland - the price is right! | ||
Scotland / hybrid 2-3 dpw office-based - Negotiable |
Projects Actuary | ||
South East / hybrid 1-2 dpm office-based - Negotiable |
Technical Business Analyst - Internat... | ||
Bermuda - Negotiable |
Senior Pensions Manager - Assurance | ||
Flexible / hybrid 2-3 days p/w office-based - Negotiable |
Head of Pricing | ||
London - Negotiable |
Consultancy Bonanza! | ||
UK-wide / London / hybrid - Negotiable |
Service Delivery Manager - Pensions | ||
Scotland / remote / 2 dpm in the office - Negotiable |
Life Actuarial Student – Risk | ||
Glasgow / hybrid 2 dpw office-based - Negotiable |
ALM Strategy Specialist | ||
Bermuda - Negotiable |
Senior Casualty Reinsurance Actuary | ||
London - £140,000 Per Annum |
Senior Pensions Administrator - Midlands | ||
Birmingham / hybrid - Negotiable |
Senior Pensions Administrator - Scotland | ||
Scotland / hybrid 2 days per month office-based - Negotiable |
Investment Analyst | ||
South East / hybrid - Negotiable |
International Capital Management Actuary | ||
Bermuda - Negotiable |
VP Reserving Actuary | ||
London - £150,000 Per Annum |
Calling all BPA analysts! | ||
North West / hybrid 50/50 - Negotiable |
Financial Planning & Analysis Actuary | ||
London/Hybrid - Negotiable |
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