Are Taxpayers Properly Paying the Federal Foreign Insurance Excise Tax?
The article examines whether foreign insurance companies are properly paying the U.S. federal foreign insurance excise tax under Section 4371. The ruling imposes a federal excise tax (FET) certain premiums paid to a foreign insurer not engaged in a U.S. trade or business. A premium payment includes any consideration paid for assuming and carrying the risk or obligation, and includes any additional assessment or charge paid under the insurance contract. The FET must be paid by the person who makes the premium payment to the foreign insurer/reinsurer.
