S.1987

Amends the Internal Revenue Code to establish special rules for financial guaranty insurance companies under passive foreign investment company rules.

This bill amends the Internal Revenue Code to provide special rules for determining if financial guaranty insurance companies qualify as insurance corporations under passive foreign investment company rules. It includes provisions for the inclusion of unearned premium reserves in applicable insurance liabilities, clarifications on financial statement reporting, and the application of certain rules to periods after a company ceases to be treated as a passive foreign investment company. The bill also mandates the Secretary of the Treasury to issue regulations and guidance for these companies.