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Proposed regulations that provide guidance on the determination of whether a qualified investment entity ("QIE") is domestically controlled by removing a rule in previously promulgated final regulations that looks to the shareholders of certain domestic corporations in determining whether foreign persons hold directly or indirectly stock in a QIE.  In particular, final regulations published on April 24, 2024 (the 2024 final regulations”), set forth rules for determining whether stock of a QIE is considered held directly or indirectly” by foreign persons for purposes of defining a domestically controlled QIE under section 897(h)(4)(B).  TD 9992.  The 2024 final regulations define stock in a QIE that is held indirectly” by taking into account stock of the QIE held through certain entities under a limited look-through” approach.  Under that approach, only a non-look-through person” is treated as holding directly or indirectly stock of a QIE, and stock of a QIE held by or through one or more intervening look-through persons” is treated as held proportionately by the look-through person’s ultimate owners that are non-look-through persons.