In April, the I.R.S. proposed regulations (REG-108214-15) that provide exceptions for P.F.I.C. treatment for offshore insurance companies, unless they are formed by hedge funds intending to defer or reduce tax. Andrew P. Mitchel and Christine Long look at comments of industry representatives. Many professionals deem these regulations too restrictive, needlessly subjecting legitimate insurance businesses to the harsh tax treatment of P.F.I.C.’s.