Executive summaryIn 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 regulations are largely consistent with the proposed PFIC regulations released on 10 July 2019 (the 2019 proposed regulations) but contain several significant changes. For discussion of the 2019 proposed regulations, see EY Global Tax Alert, US proposed regulations provide guidance on passive foreign investment companies, clarify...