Law360, New York (April 30, 2015, 10:03 AM EDT) -- On April 23, 2015, the IRS and Treasury Department released proposed treasury regulations affecting insurance companies under the "passive foreign investment company" (PFIC) rules of the internal revenue code. The proposed regulations come in the wake of recent attention in the press and inquiries from Sen. Ron Wyden, D-Ore., regarding foreign insurance companies organized by or otherwise associated with hedge funds that manage all or a substantial portion of the insurance companies' investment assets. These arrangements have been portrayed as tax avoidance schemes. The proposed regulations, however, are not explicitly limited to hedge fund-linked insurance companies and could impact more traditional "offshore" insurance companies....