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October 27, 2010: Reinsurance Association of America (RAA)


FATCA Comment Letter Submitted to the Department of the Treasury Global FATCA Development

On October 27th, the Reinsurance Association of American (RAA) submitted comments to the Department of the Treasury and to the Internal Revenue Service (IRS) in response to Notice 2010-60.

RAA is a U.S. national trade association representing 24 property and casualty companies specializing in reinsurance. Several of their recommendations offered include:

  • Requesting that categorization as an Non-Financial Foreign Entities (NFFE) be determined by the types of products an insurer actually writes, as opposed to the types of contracts they are authorized to write.
  • That all reinsurance companies be treated as NFFEs.
  • Treating all holding companies as NFFEs unless they have “financial accounts.”

A copy of the RAA letter, as originally published by Tax Analysts, is attached.

Contact FATCA Leader  for further information.

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