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Tax Reform Act of 1984 TRA

The Tax Reform Act of 1984 includes two sections that increased the tax bill of an offshore captive insurer defined as a controlled foreign corporation.

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One section redefined income related to the insurance of US-based risks as US-source income instead of foreign-source income. Another section made income from the insurance of related risks in foreign countries taxable in the current year. The net effect of these two changes was to eliminate most tax advantages for an offshore single-parent captive.