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TREAS/IRS

RIN: 1545-AX78

Publication ID: Fall 2008

Title: Definition of Passive Foreign Investment Company (PFIC) Under Section 1297
Abstract: This regulation defines a passive foreign investment company (PFIC) under section 1297(a) and the terms "passive income" and "passive asset" under section 1297(b). The regulation will also set forth the exceptions to the terms "passive income" and "passive asset," and provide guidance on the applicability of the look-through rule under section 1297(c), in cases involving PFICs that own 25 percent or more of a lower-tier foreign subsidiary. In addition, the regulation will provide guidance under section 1297(e), regarding the overlap rule between a controlled foreign corporation and a PFIC.
Agency: Department of the Treasury(TREAS)	Priority: Substantive, Nonsignificant
RIN Status: Previously published in the Unified Agenda	Agenda Stage of Rulemaking: Proposed Rule Stage
Major: No	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 7805    26 USC 1297

Legal Deadline:  None

Timetable: Action Date FR Cite NPRM  12/00/2008

Additional Information: REG-100427-00 Drafting attorney: Paul J. Carlino (202) 622-3840 Reviewing attorney: Ethan A. Atticks (202) 622-3840 Valerie A. Mark Lippe (202) 622-3840 Treasury attorney: David Ernick (202) 622-1754 CC: INTL
Regulatory Flexibility Analysis Required: No	Government Levels Affected: None
Small Entities Affected: No	Federalism: No
Included in the Regulatory Plan: No
RIN Data Printed in the FR: No
Agency Contact: Paul J. Carlino Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 622-3840 Email: paul.j.carlino@irscounsel.treas.gov