Bills · HR 2567
IN COMMITTEE· 119TH CONGRESS
House BillHR 2567Taxation
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.
This bill updates the tax code to ensure that foreign bond insurance companies are correctly identified as active businesses rather than passive investment funds, protecting American investors from unfair taxes.AI-written
INTRO APR 1· LAST ACTION APR 1
READING
6MIN
COSPONSORS
3BIPARTISAN
READER REACTIONS0 TOTAL
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- Introduced only
tl;dr
AI-writtenAdjusts IRS math for foreign bond insurance companies so American investors aren't hit with 'tax haven' penalties for owning stock in legitimate international businesses.
LEGISLATIVE PROGRESS
STEP 2 / 8Introduced
In Committee
Reported
Passed House
Passed Senate
Conference
To President
Became Law
WHAT THE BILL DOES
AI-writtenCurrently, because of a technicality in how insurance liabilities are calculated, some legitimate bond insurers are being labeled as 'passive' investment funds by the IRS. This causes American investors to face significantly higher tax rates and complex filing requirements. If this bill passes, it provides a clearer, industry-specific path for these companies to prove they are active businesses, preventing accidental tax penalties. Without it, American investment in the international bond insurance market may continue to be discouraged by the threat of punitive tax treatment.
KEY PROVISIONS
4AI-extractedPROVISION 01
Modifies the calculation of insurance liabilities for financial guaranty companies to include 'unearned premium reserves.'
This allows bond insurers to count more of their future obligations as current liabilities, which helps them pass the test to be considered a legitimate business rather than a tax-haven fund.
PROVISION 02
Sets specific financial ratios, such as a 15-to-1 financial guaranty exposure or a 9-to-1 state and local bond exposure.
These benchmarks provide clear, objective guardrails for the IRS to distinguish between active insurers and passive investment shells.
PROVISION 03
Establishes a 'grace period' for the years 2018 through 2024.
This protects investors from being retroactively taxed for previous years when these companies might have failed the older, less specific tax tests.
PROVISION 04
Requires U.S. persons owning interests in certain non-publicly traded foreign corporations to report specific information to the Treasury Department.
This increases transparency and ensures that the IRS can verify the company is actually meeting the new insurance requirements.
SPONSORSHIP
1 + 3
D· Wisconsin
YRS IN OFFICE
21
BILLS LED
34
COSPONSOR BREAKDOWNBIPARTISAN · 66%
DEM 1 REP 2 IND 0
ACTION TIMELINE
2 EVENTSAPR 1
Introduced in House
APR 1
Referred to the House Committee on Ways and Means.
BILL INFO
TypeHouse Bill
NumberHR 2567
Congress119th
StatusIn Committee
IntroducedApr 1, 2025
Last actionApr 1, 2025
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IN COMMITTEE· 119TH CONGRESS · WAYS AND MEANS COMMITTEE · INTRODUCED APR 1, 2025
House BillHR 2567Taxation
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.
This bill updates the tax code to ensure that foreign bond insurance companies are correctly identified as active businesses rather than passive investment funds, protecting American investors from unfair taxes.AI-written
INTRODUCED APR 1, 2025· LAST ACTION APR 1, 2025
PASSAGE CHANCES
—%
READING
6 min
COSPONSORS
3
COMPLEXITY
