EYUS final and proposed PFIC regulations provide a mix of favorable and unfavorable provisions
|Tax Alerts, National/Federal Taxation, L ...|United States
Executive summary
In final and proposed regulations released on 4 December 2020, the United States (US) Treasury Department (Treasury) and Internal Revenue Service (IRS) provide guidance on the passive foreign investment company (PFIC) rules under Internal Revenue Code1 Sections 1291, 1297 and 1298 (the final PFIC regulations and the 2020 proposed regulations, respectively).
The final PFIC regulatio…
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