IRS CCA: Foreign Insurer Electing to Be Treated as Domestic Has FBAR Filing Requirement (IRC §953)

Foreign insurance company making an election under I.R.C. §953(d) to be treated as a domestic life insurance company has an FBAR filing requirement, the Chief Counsel’s Office informally advised. Entities created, organized, or formed under the laws of the United States have an FBAR filing requirement per 31 C.F.R. §1010.350(b), the Chief Counsel’s Office stated. [CCA 202225008]

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