Internal Revenue Service January 25, 2022 – Federal Register Recent Federal Regulation Documents
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Guidance on Passive Foreign Investment Companies and Controlled Foreign Corporations Held by Domestic Partnerships and S Corporations and Related Person Insurance Income
This document contains proposed regulations regarding the treatment of domestic partnerships and S corporations that own stock of passive foreign investment companies (``PFICs'') and their domestic partners and shareholders (the ``proposed regulations''). The proposed regulations also provide guidance regarding the determination of the controlling domestic shareholders of foreign corporations, the owner of a controlled foreign corporation (``CFC'') or qualified electing fund (``QEF'') that makes an election under section 1411, the treatment of S corporations with accumulated earnings and profits under subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code (``subpart F'' of the ``Code''), and the determination and inclusion of related person insurance income (``RPII'') under section 953(c). The proposed regulations affect United States persons that own, directly or indirectly, stock in certain foreign corporations.
Guidance Under Section 958 on Determining Stock Ownership
This document contains final regulations regarding the treatment of domestic partnerships for purposes of determining amounts included in the gross income of their partners with respect to foreign corporations. The final regulations affect United States persons that own stock of foreign corporations through domestic partnerships and domestic partnerships that are United States shareholders of foreign corporations.
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