IRS Form 15674 – In the complex world of international taxation, especially for insurance-related transactions, understanding specific IRS forms is crucial for compliance and claiming exemptions. IRS Form 15674, titled “Consent to Disclose Tax Information,” plays a key role in facilitating exemptions from certain excise taxes for foreign insurers and reinsurers. This SEO-optimized guide covers everything you need to know about Form 15674, including its purpose, who should use it, how to complete it, and submission details. Whether you’re a foreign insurance company seeking treaty-based benefits or a tax professional advising on cross-border premiums, this article provides up-to-date insights based on official IRS resources.
For the latest version of the form (revised March 2025), you can download it directly from the IRS website: https://www.irs.gov/pub/irs-pdf/f15674.pdf.
What is IRS Form 15674?
IRS Form 15674 is a specialized consent form used by foreign insurers and reinsurers to authorize the IRS to disclose specific tax-related information. This disclosure allows the entity to be included on a publicly published list maintained by the IRS, which helps U.S. payers of insurance premiums claim exemptions from the federal excise tax under Section 4371 of the Internal Revenue Code.
The form is relatively straightforward and focuses on granting permission for the IRS Commissioner (or an authorized delegate) to reveal details such as the company’s legal name, principal place of business, and country of residence. It is not a general tax return or disclosure form but is tied specifically to treaty-based exemptions for insurance premiums paid to foreign entities.
Unlike broader consent forms like Form 8821 (Tax Information Authorization), Form 15674 is tailored for the insurance industry’s international tax framework, ensuring transparency while protecting sensitive information under privacy laws.
The Purpose of IRS Form 15674
The primary purpose of Form 15674 is to enable foreign insurers or reinsurers with effective closing agreements to be added to the IRS’s published list of entities eligible for exemptions from the Section 4371 excise tax. This tax is imposed on premiums paid to foreign insurers or reinsurers for policies covering U.S. risks, but exemptions may apply under U.S. income tax treaties if certain conditions are met.
By signing and submitting Form 15674, the entity consents to the disclosure of limited information, which in turn allows U.S. taxpayers (such as policyholders or intermediaries) to verify the foreign company’s eligibility for the exemption before filing their returns. This process is outlined in revenue procedures like Rev. Proc. 2003-78 (as amended by Rev. Proc. 2015-46), which govern closing agreements for treaty-based exemptions.
Key benefits include:
- Streamlining exemption claims for U.S. payers.
- Enhancing compliance with international tax treaties.
- Providing public verification through IRS publications in the Internal Revenue Bulletin.
Note that the published lists are not conclusive proof of a valid closing agreement; interested parties must contact the foreign company directly for confirmation.
Who Needs to File IRS Form 15674?
Form 15674 is primarily for foreign insurers or reinsurers that:
- Have entered into a closing agreement with the IRS under relevant revenue procedures (e.g., Rev. Proc. 2003-78, Rev. Proc. 92-39, Rev. Proc. 87-13, or Rev. Proc. 84-82).
- Wish to be included on the IRS’s list of entities with such agreements to facilitate exemption claims by U.S. taxpayers.
This form is not required for all foreign insurers but is optional for those seeking public listing. U.S. taxpayers remitting premiums do not file this form; instead, they rely on the list or direct knowledge of the closing agreement to claim the exemption on their excise tax returns.
Special considerations apply to treaties with countries like Cyprus, Finland, France, Germany, Ireland, and Sweden, where exemptions may not apply if premiums are paid to an office outside the company’s residence country. Additionally, post-1989 premiums under U.S.-Barbados or U.S.-Bermuda treaties are subject to the tax regardless of treaty provisions.
If you’re a foreign entity without a closing agreement, refer to the IRS’s Federal Excise Tax Exemption Program for guidance on initiating one.
How to Fill Out IRS Form 15674: Step-by-Step?
While the exact layout may vary slightly with revisions, Form 15674 typically requires the following information based on official descriptions:
- Entity Information: Provide the company’s legal name, principal place of business, and country of residence. This is the core data that will be disclosed.
- Consent Statement: The form includes a pre-written consent clause authorizing the IRS to disclose the above details for the purpose of the exemption list.
- Signature and Date: An authorized representative (e.g., officer or director) must sign the form, attesting to the accuracy and consent.
- Additional Details: Include any references to the closing agreement, such as the effective date or revenue procedure under which it was entered.
Always download the most current version from the IRS website to ensure compliance. If you’re unsure about any section, consult a tax advisor specializing in international insurance taxation.
How to Submit IRS Form 15674?
Once completed, email the signed Form 15674 to Sammi Cen at [email protected]. There is no filing fee, and submission is electronic for efficiency. The IRS will review the consent and, if approved, add the entity to the next published list in the Internal Revenue Bulletin.
Processing times can vary, so submit well in advance if you’re relying on the listing for upcoming tax periods. Keep a copy of the submitted form and any correspondence for your records.
Common Questions About IRS Form 15674
Is Form 15674 Mandatory?
No, it’s optional but recommended for entities wanting public visibility on the IRS list to ease exemption claims for U.S. payers.
What Happens If I Don’t File It?
Your closing agreement remains valid, but U.S. taxpayers may need to verify it directly with you rather than relying on the published list.
Are There Penalties for Incorrect Filing?
Providing false information could lead to penalties under IRS rules, so ensure accuracy.
How Does This Relate to Other IRS Forms?
It’s distinct from forms like Form 720 (Quarterly Federal Excise Tax Return) used by U.S. payers or Form W-8ECI for withholding exemptions.
Conclusion
IRS Form 15674 is an essential tool for foreign insurers and reinsurers navigating U.S. excise tax exemptions under Section 4371. By consenting to limited disclosure, entities can simplify the process for U.S. taxpayers and ensure smoother international transactions. Always use the latest form version and consult professionals for personalized advice.
For more details on closing agreements or treaty provisions, visit the IRS’s international business resources. Stay compliant and informed to avoid unnecessary tax burdens in cross-border insurance dealings.