‘qualified investment income dividend’ means the 
portion of any dividend distributed by a catastrophic 
risk transfer company— 
‘‘(A) which is attributable to investment 
income from qualified investments earned dur-
ing a taxable year in which the catastrophic 
risk transfer company meets the requirements 
of subsection (b) of section 860M and sub-
section (a) of section 860N, and 
‘‘(B) which is reported by the company as 
a qualified investment income dividend in writ-
ten statements furnished to its security hold-
ers.’’. 
(2) FOREIGN CORPORATIONS.—Section 881 of 
such Code is amended by redesignating subsection 
(f) as subsection (g) and by inserting after sub-
section (e) the following: 
‘‘(f) EXEMPTION FOR QUALIFIED INVESTMENT IN-
COME DIVIDENDS
OF CATASTROPHIC RISK TRANSFER 
COMPANIES.— 
‘‘(1) IN GENERAL.—Except as provided in para-
graph (2), no tax shall be imposed under paragraph 
(1)(A) of subsection (a) on any qualified investment 
income dividend received from a catastrophic risk 
transfer company which meets the requirements of 
VerDate Sep 11 2014 
20:42 Mar 17, 2025
Jkt 059200
PO 00000
Frm 00022
Fmt 6652
Sfmt 6201
E:\BILLS\H1481.IH
H1481
ssavage on LAPJG3WLY3PROD with BILLS
section 860M(a) for the taxable year with respect to 
which the dividend is paid. 
‘‘(2) EXCEPTIONS.—Paragraph (1) shall not 
apply any dividend described in section 871(n)(2). 
‘‘(3) QUALIFIED
INVESTMENT
INCOME
DIVI-
DEND.—For purposes of this paragraph, the term 
‘qualified investment income dividend’ has the same 
meaning given such term by section 871(n)(3).’’. 
(c) CONFORMING AMENDMENT.—The table of parts 
for subchapter M of chapter 1 of the Internal Revenue 
Code of 1986 is amended by adding at the end the fol-
lowing new item: 
‘‘PART V—CATASTROPHIC RISK TRANSFER COMPANIES.’’. 
SEC. 3. STATE TAXATION OF REINSURANCE PREMIUMS OF 
CATASTROPHIC RISK TRANSFER COMPANIES. 
(a) PREVENTION OF DOUBLE TAXATION.—A taxing 
jurisdiction other than the State under the laws of which 
a catastrophic risk transfer company is created or orga-
nized shall not impose a premium tax on any premiums 
paid to, or received by, such company on a policy of rein-
surance. 
(b) COORDINATION
OF RATE
OF PREMIUM TAX 
WITH TAX ON FOREIGN REINSURERS.—If a State allowed 
under subsection (a) imposes a premium tax on a cata-
strophic risk transfer company on premiums on a policy 
of reinsurance, the amount of such tax shall not exceed 
VerDate Sep 11 2014 
20:42 Mar 17, 2025
Jkt 059200
PO 00000
Frm 00023
Fmt 6652
Sfmt 6201
E:\BILLS\H1481.IH
H1481
ssavage on LAPJG3WLY3PROD with BILLS
the tax which would have been imposed under section 
4371 of the Internal Revenue Code of 1986 if such pre-
miums were paid to a foreign insurer or reinsurer. 
(c) DEFINITIONS.—For purposes of this section— 
(1) CATASTROPHIC
RISK
TRANSFER
COM-
PANY.—The term ‘‘catastrophic risk transfer com-
pany’’ has the meaning given such term by section 
860M of the Internal Revenue Code of 1986. 
(2) POLICY OF REINSURANCE.—The term ‘‘pol-
icy of reinsurance’’ has the meaning given such term 
by section 4372(f) of such Code. 
(3) TAXING JURISDICTION.—The term ‘‘taxing 
jurisdiction’’ means any of the several States, the 
District of Columbia, or any territory or possession 
of the United States, any municipality, city, county, 
or any other political subdivision within the terri-
torial limits of the United States with the authority 
to impose a premium tax on a policy of reinsurance. 
Æ 
VerDate Sep 11 2014 
20:42 Mar 17, 2025
Jkt 059200
PO 00000
Frm 00024
Fmt 6652
Sfmt 6301
E:\BILLS\H1481.IH
H1481
ssavage on LAPJG3WLY3PROD with BILLS