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%, as in the proposed regulations).The Final Regulations retain the proposed regulations' treatment of qualified foreign pension funds (QFPFs), qualified controlled entities (QCEs) and international organizations (IOs) as foreign persons for purposes of the domestically controlled QIE exception.A transition rule relieves taxpayers...