On 25 January 2022, the United States (US) Treasury Department and the Internal Revenue Service (IRS) published final regulations (T.D. 9960) treating domestic partnerships as aggregates (i.e., not as entities) for many subpart F purposes. These regulations finalize, with limited changes, regulations originally proposed in 2019 (See EY Global Tax Alerts, US final and proposed GILTI and subpart F regulations include favorable and unfavorable provisions for taxpayers, dated 21 June 2019, and US final, temporary and proposed regulations on GILTI and ownership attribution affect domestic pass-through owners and individuals, 28 June 2019.)Proposed regulations (REG-118250-20) also were issued that would extend the aggregate...