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No Bright-Line Test In IRS Hedge Fund Reinsurance Regs

By Eric Kroh (April 23, 2015, 1:32 PM EDT) -- The Internal Revenue Service in proposed regulations released Thursday declined to set out a hard and fast rule — at least right away — for foreign insurance companies to determine if they qualify for special exceptions to tax rules on passive foreign income, which the IRS says are used to shelter hedge fund earnings from taxes....

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