Corrections to final regulations on the determination of whether a foreign corporation is treated as a passive foreign investment company (PFIC) for purposes of the Internal Revenue Code, and the application and scope of certain rules that determine whether a U.S. person that indirectly holds stock in a PFIC is treated as a shareholder of the PFIC, the IRS released March 4. The changes impact the Preamble and make just sentence construction changes. Effective March 5, 2021, and applicable on or after January 15, 2021. [T.D. 9936, RIN 1545-BO59, 86 Fed. Reg. __ (Mar. 5, 2021)]
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