To amend the Internal Revenue Code of 1986 to prevent the use of reinsurance with foreign persons to enable domestic nonlife insurance companies to evade United States income taxation.

Amends the Internal Revenue Code to provide, with specified exceptions, that if a domestic person reinsures a United States risk with a related foreign reinsurer (as defined by this Act) then: (1) such person's investment income shall incur certain increases; and (2) certain excise taxes shall not apply to the foreign reinsurer's premiums.