IRS Prop. Reg.: PFIC Shareholders Would Reflect Aggregate Approach (IRC §1291)

Proposed rules that would provide guidance on the treatment of domestic partnerships and S corporations that own stock of passive foreign investment companies (PFICs) and their domestic partners and shareholders, issued by the IRS Jan. 24. The proposed regulations also provide guidance regarding the determination of the controlling domestic shareholders of foreign corporations, the owner of a controlled foreign corporation (CFC) or qualified electing fund (QEF) that makes an election under §1411, the treatment of S corporations with accumulated earnings and profits under subpart F, and the determination and inclusion of related person insurance income (RPII) under §953(c) ...