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Treasury releases final and proposed PFIC regulations

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December 2020

Overview

Treasury and the IRS on December 4 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 July 11, 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.

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