Euler Hermes Rackversicherung A.G. Richtiplatz 1, Postfach CH-8304 Wallisellen Switzerland Date: February 8, 2007 If you wish to be represented by a third party regarding the closing contract, please attach an IRS form 2848 when you apply. Please use the latest available version of IRS Form 2848. RBC Reinsurance (Ireland) Ltd. Suite A5, Beacon Ct Sandyford Dublin 18 Ireland Effective Date: April 1, 2001 Without a conclusion agreement, even if the foreign insurance company is domiciled in a contracting country, it can be difficult to prove that the contract exemption is available. Other exceptions may be possible. B for example, where the foreign insurance company has a U.S. branch and the policy was purchased by the branch, or if the insurance company has decided to be treated tax as a U.S. company. The persons responsible for the delivery under the concluding agreement are persons who are employees, executives or directors of the applicant, with whom the FET IRS can resolve issues arising from the contract and who are entitled to sign on behalf of the subject. For each person designated as the person in charge, please include a list of the parties, including their name, title, business address, phone, fax and email address.

Make sure it is signed by someone with the authority to sign the application and that the person`s name is printed below and that the form is dated. On the next page, you will find a standard form for the list of PDF files for those responsible as part of the agreement. Warning: Section 6139 of the Technical and Miscellaneous Revenue Act of 1988 (P.L. 100-647) provides that no provision of the U.S. S.-Barbados or the Lower United States Convention on Income Tax (if one or both contracts are in effect on December 31, 1989) does not prevent the application of the excise on premiums payable on insurance coverage for the periods following December 31, 1989. In its latest guide – a memorandum – the IRS stated that excise controllers should collect detailed information and pass it on to the International Excise Tax Group when an auditor meets with a FCIC. Information to be collected from the examiner includes the name, employer identification number and home of the subsidiary. In addition, the auditor must indicate the amount of premiums insured with the subsidiary and the amount of premiums reinsured by the subsidiary from reinsurance companies. Finally, the examiner must indicate whether the branch in captivity has conducted an election under Section 953 (d) and whether the FCIC has entered into a conclusion agreement. The IRS occasionally focuses on a particular group of taxpayers and, if so, audit rates increase significantly.

Foreign insurance companies (FCCCs) have been a group to which the IRS has had a particular interest since at least 2008. Over the past four years, the IRS has issued countless guidelines for IRS auditors for information and various audit methods. In addition, the IRS announced a voluntary compliance program for THE FCIC (see 2008-18 announcement). The federal insurance excise duty is recorded quarterly on Form 720, the quarterly federal tax return. The U.S. company may have excise obligations as a result of other insurance contracts, such as. B than those it entered into directly with a foreign insurance company or other excise obligations for which it could have filed returns on Form 720 in the past.