Revenue Ruling 2016-03 announces that the Internal Revenue Service (IRS) has reconsidered Revenue Ruling 2008-15, 2008-1 C.B. 633, in view of the decision of the United States Court of Appeals for the District of Columbia Circuit in the case of Validus Reinsurance, Ltd. v. United States, 786 F.3d 1039 (2015). As a result, the IRS will no longer apply the one-percent excise tax imposed by section 4371(3) to premiums paid on a policy of reinsurance issued by one foreign reinsurer to another foreign insurer or reinsurer under the situations described in Rev. Rul. 2008-15. Rev. Rul. 2008-15 is hereby revoked.
Rev. Rule 2016-3 will be in IRB 2016-3, dated Jan. 19, 2016.