The Treasury Department issued proposed regulations relating to passive foreign investment companies (PFICs). The agency published the guidance (REG-118250-20) on Jan. 25.
The proposed rules largely address the treatment of domestic partnerships and S corporations that own stock in PFICs. The rules would treat domestic partnerships and S corporations as aggregates of their partners and shareholders, respectively, for certain PFIC purposes. The proposed rules also address the controlled foreign corporation (CFC) overlap rule, purging elections, and certain PFIC information reporting requirements, as well as several non-PFIC topics.
Click the BTAX OnPoint: 2022 Proposed PFIC Rules.
The proposed regulations ...
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