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IRS Issues Final PFIC Ownership Regulations
The IRS has issued final
regulations (TD 9936) regarding how to determine if a
foreign corporation is a passive foreign investment company (PFIC)
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.
On July 11, 2019, the IRS published proposed regulations
(REG-105474-18) under Sections 1291, 1297, and 1298 (see our prior
coverage
here) in the Federal Register (84 FR 33120) (the
“proposed regulations” or “2019 proposed