To make election 953(d), a prisoner must ensure that 10% of his fortune is in the United States and maintains a U.S. office. If the prisoner does not do so, he must execute a conclusion agreement and a credit to ensure the payment of taxes with the IRS. Mexico remains the largest source of captive transactions for Bermuda, which is understandable as the first Tax Information Agreement (TIEA) was concluded between an offshore jurisdiction and a Latin American country between Bermuda and Mexico. Several income tax treaties provide for an exemption for the FET, subject to certain restrictions. As a threshold, the foreign insurance company must meet the limit of the service item provided for in a contract to qualify for contractual services. In addition, most income tax agreements providing for an exemption for the FET grant only a qualified exemption.