Tax Notes has published a report from the IRS regarding the domestic asset/liability percentages and domestic yields needed by foreign life insurance companies so that such companies can find their minimum effectively connected net investment income. This revenue procedure has been put forth in order for foreign life insurance companies to estimate what taxes they need to pay from December 31, 2007 and onwards.The principle author of this revenue computation is Shiela Ramaswamy of the Office of Associate Chief Counsel (International).
See IRS, "IRS Releases Domestic Asset/Liability Percentages for Foreign Life Insurance Companies," 16 2009 TNT 151-16, August 7, 2009.
Posted by Raj Chudgar, Associate Editor, Wealth Strategies Journal
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