Referred to the Committee on Ways and Means, and in addition to the Committee on the Judiciary, for a period to be subsequently determined by the Speaker, in each case for conside…
Creates a new tax regime and legal definition for “catastrophic risk transfer companies” (state‑licensed special purpose insurers) that issue securities and accept catastrophic insurance or reinsurance risks. Establishes qualification rules, corporate taxation rules, dividend characterization and timing, withholding exemptions for certain foreign and nonresident investors, and limits on other jurisdictions taxing reinsurance premiums.
Liberals focus on revenue loss and public safeguards; conservatives focus on market capacity benefits
Technical, committee-centric tax bill likely to advance in Ways and Means if industry support exists; revenue and state-tax effects may prompt some opposition.
Creates a new tax regime and legal definition for “catastrophic risk transfer companies” (state‑licensed special purpose insurers) that issue securities and accept catastrophic insurance or reinsurance risks.
Establishes qualification rules, corporate taxation rules, dividend characterization and timing, withholding exemptions for certain foreign and nonresident investors, and limits on other jurisdictions taxing reinsurance premiums.
The bill permits series treatment for protected cells, requires full collateralization of covered risk, and includes procedural rules for failures, distributions, and professional expense deductions.
Narrow, technical design improves odds, but fiscal impacts, state tax preemption, international investor treatment, and high complexity reduce standalone viability.
How solid the drafting looks.
Liberals focus on revenue loss and public safeguards; conservatives focus on market capacity benefits
These are examples from the analysis, not a ranked list of the most-affected groups.
Liberals focus on revenue loss and public safeguards; conservatives focus on market capacity benefits
Sees potential public benefits from private catastrophe risk capacity but is wary of special tax treatment favoring financial actors.
Concerned about revenue loss, reduced state tax bases, and insufficient consumer or public‑interest safeguards.
Wants stronger transparency, anti‑abuse rules, and climate‑risk accountability before full support.
Views the bill as a pragmatic effort to expand private catastrophe risk capacity while clarifying tax treatment.
Generally favorable if accompanied by safeguards against tax avoidance and clarity for state regulators.
Wants cost estimates and limited technical fixes to prevent unintended loopholes.
Likes market-based expansion of catastrophe risk transfer and incentives attracting capital.
Views the measure as pro-growth, encouraging U.S. domiciles and private solutions to disaster risk.
Some concern about federal intrusion into state insurance taxation and any complex corporate carve-outs.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Narrow, technical design improves odds, but fiscal impacts, state tax preemption, international investor treatment, and high complexity reduce standalone viability.
The bill has not accumulated any surfaced votes yet.
Liberals focus on revenue loss and public safeguards; conservatives focus on market capacity benefits
Narrow, technical design improves odds, but fiscal impacts, state tax preemption, international investor treatment, and high complexity red…
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