The U.S. IRS and Treasury have issued the final regulations (TD 9936) on Guidance on Passive Foreign Investment Companies. The regulations were published in the Federal Register on 15 January 2021 and are generally effective on 14 January 2021.
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SUMMARY:
This document contains final regulations regarding the determination of whether a foreign corporation is treated as a passive foreign investment company ("PFIC") for purposes of the Internal Revenue Code ("Code"), and the a…