# 119-hr-2567: To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules.

119-hr-2567, To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules., is a 119th Congress bill sponsored by Rep. Moore, Gwen [D-WI-4] (D-WI); status introduced; PRIA reads it as touching household money (as of 2026-04-21).

- Canonical: https://policyrisk.com/legislation/119-hr-2567
- As of: 2026-04-21
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Bill: 119-hr-2567
- Congress: 119
- Title: To amend the Internal Revenue Code of 1986 to provide special rules for purposes of determining if financial guaranty insurance companies are qualifying insurance corporations under the passive foreign investment company rules.
- Status: introduced
- Introduced: 2025-04-01
- Sponsor: Rep. Moore, Gwen [D-WI-4] (D-WI)
- Cosponsors: 3
- Policy area: Taxation
- Touches household money: yes
- Last recorded action: 2026-04-21

## Summary

**Special PFIC (passive foreign investment company) rules for financial guaranty insurers.** The bill would create tailored PFIC tests and reporting rules for financial guaranty insurance companies, add clear definitions of exposure ratios, and set a transitional grace period for certain stock treatment. - Financial guaranty insurers would be able to count unearned premium reserves as part of their insurance liabilities for PFIC tests when GAAP limits reserve reporting and the company meets exposure ratios of at least 15-to-1 for financial guaranty exposure or 9-to-1 for state or local bond exposure. - U.S. owners of specified non-public foreign corporations would face new Treasury reporting requirements if the foreign firm would be a PFIC absent the special rules. - The bill would create a special grace period and transitional rules for qualified FGIC stock for taxable years after Dec. 31, 2024, including an alternate 8-to-1 test for certain earlier years and authority for the Secretary to issue regulations on revoking PFIC elections and handling periods after PFIC status ends.

## Cosponsors (3)

- Rep. Smith, Adrian [R-NE-3] (R-NE), 2025-04-01T00:00:00.000Z
- Rep. Sewell, Terri A. [D-AL-7] (D-AL), 2026-01-06T00:00:00.000Z
- Rep. Miller, Max L. [R-OH-7] (R-OH), 2026-01-06T00:00:00.000Z

## Provisions PRIA read

- PFIC grace period for guaranty insurers: benefit, medium. If enacted, your PFIC holding period would skip a grace period for stock in a qualified financial guaranty insurer. The grace period runs from the company’s first tax year after Dec 31, 2017 through its last tax year beginning before Jan 1, 2025. For years ending before Jan 1, 2019, the 9-to-1 test…
- New reporting for some foreign company owners: cost, low. If enacted, U.S. persons who own some non-public foreign companies could face a new filing. If you claim the company is not a PFIC, Treasury could require you to report details about it. This applies when the company would be a PFIC without the insurance-company exception and its interests are not…
- PFIC rules for financial guaranty insurers: mixed, medium. If enacted, some financial guaranty insurers would be treated as meeting an alternative PFIC test. The Treasury Secretary would decide if they follow the October 2008 NAIC guideline. These insurers could count unearned premium reserves as insurance liabilities, but only if three rules are met. GAAP…

## Related bills

- 119-hr-9877: Health Equity and Accountability Act of 2026
- 119-hr-6900: American Affordability Act of 2025
- 119-hr-2548: Sanctioning Russia Act of 2025
- 119-hr-33: To amend the Internal Revenue Code of 1986 to provide special rules for the taxation of certain residents of Taiwan with income from sources within the United…
- 119-hr-2725: Affordable Housing Credit Improvement Act of 2025
- 119-hr-9250: Great American Outdoors Act 250

## Sources
- [119-hr-2567 on Congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/2567)

## Related
- [119-hr-9877: Health Equity and Accountability Act of 2026](https://policyrisk.com/legislation/119-hr-9877)
- [119-hr-6900: American Affordability Act of 2025](https://policyrisk.com/legislation/119-hr-6900)
- [119-hr-2548: Sanctioning Russia Act of 2025](https://policyrisk.com/legislation/119-hr-2548)
- [119-hr-33: To amend the Internal Revenue Code of 1986 to provide special rules for the tax…](https://policyrisk.com/legislation/119-hr-33)
- [119-hr-2725: Affordable Housing Credit Improvement Act of 2025](https://policyrisk.com/legislation/119-hr-2725)
- [119-hr-9250: Great American Outdoors Act 250](https://policyrisk.com/legislation/119-hr-9250)
- [All bills in Congress](https://policyrisk.com/legislation)

Source: PRIA, https://policyrisk.com/legislation/119-hr-2567 (as of 2026-04-21).