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TREAS/IRS | RIN: 1545-BI25 | Publication ID: Fall 2015 |
Title: Guidance Regarding the PFIC Income Test and Certain PFIC Subsidiaries | |
Abstract: This document contains proposed regulations regarding the treatment of certain income or gain received or accrued by a foreign corporation in a taxable year for purposes of determining whether such foreign corporation is a passive foreign investment company (PFIC) in such taxable year. Regulations under section 1297(c) provide rules for classifying gains recognized by a foreign corporation from the sale or exchange of stock of a 25 percent-owned (by value) foreign subsidiary corporation for purposes of the passive income test of section 1297(a)(1). Regulations under section 1298(b)(3) apply the change-of-business exception provided by section 1298(b)(3) to a foreign corporation's sale or exchange of all or a portion of the stock of a 25 percent-owned (by value) corporation described in section 1297(c). The regulations affect certain foreign corporations and United States persons who own (directly or indirectly) stock interests in such foreign corporations. | |
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 U.S.C. 1298(g) 26 U.S.C. 7805 |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-141373-08 Drafting attorney: Rose E. Jenkins (202) 317-6934 Reviewing attorney: Barbara E. Rasch (202) 317-6934 Treasury attorney: Brett York (202) 622-1285 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: Rose E. Jenkins Attorney-Advisor Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6934 Fax:855 589-8671 Email: rose.e.jenkins@irscounsel.treas.gov |