Description: In PLR 202109001, the IRS ruled that a proposed assumption reinsurance transaction between related foreign parties changing the counter party obligated to a domestic corporation (“Taxpayer”) under an existing agreement did not give rise to Taxpayer being treated as making a base erosion payment (“BEP”), as Taxpayer did not receive a deduction under §832(b)(4)(A) from the amount of gross premiums written on insurance contracts during the taxable year for premiums paid for reinsurance.

Description: With more than 24 years of experience in the reinsurance market, Bruno Freire is the CEO and one of the co-founders of Austral Re, along with Vinci Partners, a private equity firm. Austral Re is a Brazilian- based multiline reinsurer which that writes business across Latin America. It has grown organically throughout the last 13 years, and had its credit rating upgraded to A- in 2023 by AM Best (it also has AAAbr from S&P). Before joining Austral, Bruno had been a reinsurance broker at Aon Re for more than 10 years, having witnessed the opening of the reinsurance market in Brazil. As we will be seen in his interview the following, he believes in a data driven analytic approach, client focused but with an underwriting mindset, as well as a strong support from actuaries and technology as key instruments to run a reinsurance company successfully.

Description: In this article, the author provides an update, as of April 2023, on the Reinsurance Section’s sponsored research in process and studies recently completed.