IRC Section 953(d) allows a controlled foreign corporation (CFC) engaged in the insurance business (an electing corporation) to elect to be treated as a U.S. corporation for purposes of imposing United States income tax. An electing corporation agrees to compute its U.S. income tax liability as if it were a domestic corporation.
For example, reinsurance company may be formed in Turks & Caicos due to that jurisdiction’s favorable insurance laws and regulations. That same reinsurance company may file an IRC section 953(d) election to be treated as a US corporation for tax purposes.
This election need only made once. The Insurance Manager will oversee this process. See IRC section 953(d) for requirements relating to the election.