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TREAS/IRS | RIN: 1545-AX78 | Publication ID: Spring 2009 |
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 |
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Timetable:
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Additional Information: REG-100427-00 Drafting attorney: Paul J. Carlino (202) 622-3840 Reviewing attorney: Ethan A. Atticks (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 |