Irs Fet Closing Agreement

1029, contains instructions on the introduction of a Section 4371 excise duty exemption on insurance premiums paid to a foreign insurer or reinsurer, if the exemption is based on the provisions of an income tax agreement to which the United States is a party. The instrument for acquiring the exemption is governed by a conclusion agreement between the foreign insurance company and the Commissioner of the Internal Revenue Service (IRS). Several income tax treaties provide for an exemption for the FET, subject to certain restrictions. As a threshold, the foreign insurance company must meet the limit of the service item provided for in a contract to qualify for contractual services. In addition, most income tax treaties, which provide for an exemption for the FET, grant only a qualified exemption. . . .

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