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

This bill exempts interests held by certain foreign insurance companies from provisions of the Foreign Investment in Real Property Tax Act of 1980 that tax foreign individuals or corporations on dispositions of investments in U.S. real property interests.

[Congressional Bills 116th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4598 Introduced in House (IH)]

<DOC>






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(l) 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.
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