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More Foreign Investment Company Rules to Come From Treasury

Nov. 17, 2020, 10:35 PM

Treasury will propose additional rules on passive foreign investment companies to address issues that may arise under upcoming final rules on the treatment of certain income by aggregate partnerships.

A final rules package will be issued on the aggregate treatment of partnerships in the context of tax code Subpart F, and a companion proposed package will likely be issued dealing with “ancillary PFIC issues that ride along with that aggregate approach,” Daniel M. McCall, deputy associate chief counsel (International) at the Internal Revenue Service, said Tuesday during an American Institute of CPAs event.

  • Final rules (RIN: 1545-BO59; REG-105474-18) and ...