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.

# Summary of HR 2567 **What the Bill Does:** This bill would modify federal tax rules to clarify how financial guaranty insurance companies are taxed. Specifically, it would adjust the Internal Revenue Code to create special rules that help determine whether these companies qualify as "qualifying insurance corporations" under passive foreign investment company (PFIC) regulations. In simpler terms, it addresses how the U.S. taxes certain foreign-owned insurance companies that guarantee financial products and investments. **Who It Affects:** The bill primarily affects financial guaranty insurance companies—businesses that provide insurance on bonds, loans, and other financial instruments to protect investors against default. It would also impact U.S.

investors and companies that own stakes in foreign financial guaranty insurers, as it could change their tax obligations. **Current Status:** The bill is currently in committee, meaning it has been introduced but not yet voted on by the full House of Representatives. Sponsor Rep. Gwen Moore (D-Wisconsin) introduced it in the 119th Congress. At this stage, the bill has not advanced to a floor vote.