US SB1987

Amends Internal Revenue Code Section 1297(f)(3) to create special rules allowing financial guaranty insurance companies to qualify as insurance corporations rather than passive foreign investment companies (PFICs) by including unearned premium reserves in their applicable insurance liabilities

Requires qualifying companies to meet specific thresholds: financial guaranty exposure of at least 15-to-1 or State/local bond exposure of at least 9-to-1, and compliance with single risk limits from the NAIC's October 2008 Financial Guaranty Insurance Guideline

Mandates new reporting requirements for U.S. persons owning interests in specified non-publicly traded foreign corporations that claim non-PFIC status, with information to be reported to the Secretary of the Treasury

Applies to taxable years beginning after December 31, 2024, with a grace period provision allowing qualified financial guaranty insurance companies to exclude the period from January 1, 2018 through December 31, 2024 when determining PFIC status for shareholders

Directs the Treasury Secretary to issue regulations addressing companies transitioning out of PFIC status, including opportunities to revoke prior elections under Sections 1295(b) or 1296(k)