View Rule

The 1992 proposed passive foreign investment company (PFIC) regulations included definitions and guidance related to distributions, dispositions, calculations, and taxation under the excess distribution regime of section 1291, as well as guidance under sections 1293 through 1295 related to PFICs that are treated as qualified electing funds. Because more than three decades have passed since issuance of the proposed regulations, Treasury and the IRS intend to repropose the remaining outstanding regulations to address issues that have arisen in the interim, including the exceptions related to non-recognition transactions.