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Pending Rules Would Clarify Tax Break for Foreign Pension Funds

July 7, 2022, 8:46 AM

The Treasury Department and the IRS are on the verge of finalizing rules aimed at making sure that foreign pension funds can take advantage of a US tax break.

The rules (REG-109826-17) under tax code Section 897(l), first proposed in 2019, would clarify that foreign pension funds and their subsidiaries are broadly eligible for a tax exemption on their gains from sales of US real-property investments—treating them the same as their U.S. pension-fund counterparts. The finalized rules are expected to be issued in the coming months, Treasury officials said recently.

The aim of the rules is to ...