Rev. Rul. 67-357

Section 4914(e) of the Internal Revenue Code of 1954 provides that the interest equalization tax shall not apply to the acquisition of stock or a debt obligation by an insurance company subject to taxation under section 802, 821, or 831 of the Code, if such stock or debt obligation is designated, in accordance with the restrictions and limitations in section 4914(e) of the Code, as part of a fund of assets established and maintained by such insurance company, in accordance with the conditions of section 4914(e) of the Code, with respect to foreign risks insured or reinsured by such company under contracts the proceeds of which are payable only in the currency of a foreign country. Held , for purposes of section 4914(e) of the Code, insurance companies taxable under section 802, 821, or 831 of the Code may designate, as a part of such a fund of assets, foreign securities which are of a country of origin or `nationality' other than that of the foreign country of operation with respect to which the fund is created. Held further , a life insurance company taxable under section 802 of the Code must establish a separate fund of assets for each foreign country of operation with respect to which it desires to obtain the benefits of exclusions under section 4914(e) of the Code, even though the same currency may be used in two or more of such countries.