Treasury and the IRS on 24 April 2024, released final regulations (TD 9992) regarding the definition of domestically controlled qualified investment entities (DC QIE) under Section 897.
The final regulations provide much needed transition rules and primarily affect foreign persons that own stock in a QIE that would be a United States real property interest (USRPI) if the QIE were not domestically controlled.
Read more in this PwC Tax Insights.