The US Treasury and the IRS have released guidance under the passive foreign investment company (PFIC) regime in the form of two regulation packages: Final Regulations (which finalize the 2019 Proposed Regulations published 11 July 2019) under Sections 1291, 1297, and 1298; and new Proposed Regulations under Sections 250, 951A, 1291, 1297, and 1298. Broadly, these regulation packages address the attribution of PFIC stock to US investors, the determination of a foreign corporation’s PFIC status, and the application of the PFIC insurance and banking exceptions.
US Treasury releases final and proposed PFIC regulations
December 14th 2020 03:05 PM • By Shelley Giberson
Shelley Giberson
Partner
