EYEY

US Treasury finalizes regulations on domestically controlled QIEs, modifying the "domestic corporation look-through rule" and providing a transition rule for certain existing QIEs

|Tax Alerts, Legislation & Policy|United States
United States

  • The final regulations (T.D. 9992, the Final Regulations) provide guidance as to when a qualified investment entity (QIE) is considered domestically controlled, narrowing the application of the domestic corporation look-through rule to privately held domestic C corporations where more than 50% of the fair market value of stock is owned, directly or indirectly, by foreign persons (rather than 25%, a…

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