On 11 July 2019, proposed regulations from the U.S. IRS and Treasury were published in the Federal Register on Guidance on Passive Foreign Investment Companies. The document withdraws proposed regulations issued in 2015 and provides new proposed regulations.
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SUMMARY:
This document contains proposed regulations under sections 1291, 1297, and 1298 of the Internal Revenue Code ("Code") regarding the determination of ownership in a passive foreign investment company within the meaning of…