The U.S. IRS and Treasury have issued a notice and request for comments concerning Treasury Decision (TD) 9360, Guidance on Passive Foreign Investment Company (PFIC) Purging Elections. The notice was published in the Federal Register on 9 November 2021, seeking comments in regard to the collection of information to substantiate the taxpayer's computation of the taxpayer's share of the PFIC's post-1986 earning and profits.
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SUMMARY:
The Internal Revenue Service (IRS), as part of its c…