| Title: Definition of Passive Foreign Investment Company (PFIC) Under Section 1297 |
| Abstract: This regulation defines a passive foreign investment company (PFIC) under section 1297(a) and the terms "passive income" and "passive asset" under section 1297(b). The regulation will also set forth the exceptions to the terms "passive income" and "passive asset," and provide guidance on the applicability of the look-through rule under section 1297(c), in cases involving PFICs that own 25 percent or more of a lower-tier foreign subsidiary. In addition, the regulation will provide guidance under section 1297(e), regarding the overlap rule between a controlled foreign corporation and a PFIC. |
| Priority: Substantive, Nonsignificant | Agenda Stage of Rulemaking: Proposed Rule |
| Major: No | Unfunded Mandates: Undetermined |
| CFR Citation: 26 CFR 1
(To search for a specific CFR, visit the
Code of Federal Regulations
)
|
| Legal Authority: 26 USC 7805; 26 USC 1297 |
| Legal Deadline: None |
| Timetable: |
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Action
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Date
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FR Cite
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| | NPRM
| | 12/00/2009
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| Additional Information: REG-100427-00 Drafting attorney: Paul J. Carlino (202) 622-3840 Reviewing attorney: Ethan A. Atticks (202) 622-3840 Treasury attorney: David Ernick (202) 622-1754 CC: INTL |
| Regulatory Flexibility Analysis Required: No | Government Levels Affected: No |
| Small Entities Affected: No | Federalism: No |
| Energy Affected: No |
Agency Contact: Paul J. Carlino
Attorney
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW
Washington
,
DC
20224
Phone:
202 622-3840
E-Mail:
paul.j.carlino@irscounsel.treas.gov
|
Agency Contact: Paul J. Carlino
Attorney
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW
Washington
,
DC
20224
Phone:
202 622-3840
E-Mail:
paul.j.carlino@irscounsel.treas.gov
|