Bloomberg – Investment vehicles set up by Paulson & Co. and Highbridge Capital Management in tax-friendly Bermuda may be under threat from the U.S. Internal Revenue Service.
The IRS, in proposed rules published Thursday, said that the favorable treatment enjoyed by insurers under the tax code shouldn’t extend to companies that borrow their insurance executives from another firm. Paulson, the New York hedge fund manager run by billionaire John Paulson, and JPMorgan Chase & Co.’s Highbridge unit both have Bermuda insurance affiliates that share most staff with other companies.