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The United States Court of Appeals for the D.C. Circuit recently affirmed a district court decision holding that the excise tax imposed under 26 USC § 4371 does not apply to wholly foreign retrocession contracts. The term “retrocession” refers to transactions in which one reinsurer buys or sells reinsurance to another reinsurer, and is sometimes referred to as “second-level” reinsurance (in contrast to the provision of reinsurance to an insurance company). The case, Validus Reinsurance, Ltd.…