The US Treasury Department and the US Internal Revenue Service (IRS) has issued Notice 2012-45 with guidance on the treatment of income from certain government bonds for purposes of determining whether a foreign corporation is a passive foreign investment company (PFIC) under section 1297 of the US Internal Revenue Code (IRC).
Under IRC section 1297(a), any foreign corporation is a PFIC if it meets either a passive income test or a passive asset test. The passive income test i…