The US Treasury Department and the Internal Revenue Service (IRS) have issued temporary regulations (TD 9650) with guidance on determining ownership of a passive foreign investment company (PFIC) and on the annual filing requirements for shareholders of PFICs. The temporary regulations also provide guidance on the information reporting requirements for certain US shareholders of foreign corporations. Definitions of PFIC terms US shareholders, whether individual or corporate, of a foreign corporation that meets the definition of a PFIC are subject to special provisions of sections 1291 through 1298 of the US Internal Revenue Code (IRC). Under these provisions, the income of...