US proposed regulations would expand scope of subpart F rules on related person insurance income
Executive summary
In proposed regulations (REG-118250-20) (the Proposed Regulations) issued 24 January 2022, the United States (US) Department of Treasury (Treasury) and the Internal Revenue Service (IRS) address, among other items, the subpart F regime on related person insurance income (RPII).1 The Proposed Regulations would expand the scope of relationships giving rise to RPII, repropo…
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