H.R. 4598

116TH CONGRESS
1ST SESSION

H.R. 4598

To amend the Internal Revenue Code of 1986 to provide an exemption
from FIRPTA for interests held by certain foreign insurance companies.

IN THE HOUSE OF REPRESENTATIVES

OCTOBER 1, 2019

Mr. SUOZZI (for himself and Mr. HOLDING) introduced the following bill;
which was referred to the Committee on Ways and Means

A BILL

To amend the Internal Revenue Code of 1986 to provide an exemption from FIRPTA for interests held by certain foreign insurance companies.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. FIRPTA EXEMPTION FOR INTERESTS HELD BY CERTAIN FOREIGN INSURANCE COMPANIES.

(a) IN GENERAL. — Section 897(l)(1) of the Internal Revenue Code of 1986 is amended —

(1) by striking "a qualified foreign pension fund shall not" and inserting "a qualified foreign  entity shall not"; and

(2) by striking "held by a qualified foreign pension fund shall be treated as such a fund" and inserting "held (directly or indirectly) by one or more qualified foreign entities shall be treated as such an entity".

(b) QUALIFIED FOREIGN ENTITY. — Section 897(1) of such Code is amended by redesignating paragraphs (2) and (3) as paragraphs (3) and (4), respectively, and by inserting after paragraph (1) the following new paragraph:

"(2) QUALIFIED FOREIGN ENTITY. — For purposes of this subsection, the term 'qualified foreign entity' means —

"(A) any qualifying insurance corporation (as defined in section 1297(f)(1)), and

"(B) any qualified foreign pension fund.".

(c) CLERICAL AMENDMENT. — The heading of section 897(l) is amended by striking "Qualified Foreign Pension Funds" and inserting "Certain Foreign Entities".

(d) EFFECTIVE DATE. — The amendments made by this section shall apply to dispositions and distributions after the date of the enactment of this Act.