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TREAS/IRS

RIN: 1545-AX78

Publication ID: Spring 2011

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: Long-Term Actions
Major: No	Unfunded Mandates: Undetermined
CFR Citation: 26 CFR 1
Legal Authority: 26 USC 1297    26 USC 7805

Legal Deadline:  None

Timetable: Action Date FR Cite Next Action Undetermined  To Be Determined

Additional Information: REG-100427-00 Drafting attorney: Barbara Rasch (202) 622-3840 Reviewing attorney: Jeffery Mitchell (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: Barbara E. Rasch Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Room 4710, Washington, DC 20224 Phone:202 622-3840 Fax:202 622-4476 Email: barbara.rasch@irscounsel.treas.gov