Treasury Department Proposed Rule

2022-27971: Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities

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Summary

This document contains proposed regulations regarding the treatment of certain entities, including qualified foreign pension funds, for purposes of the exemption from taxation afforded to foreign governments (the "proposed regulations"). The proposed regulations also address the determination of whether a qualified investment entity is domestically controlled, including the treatment of qualified foreign pension funds for this purpose.

The agency’s own summary, as published.

What this changes

Amends 1 part of the Code of Federal Regulations — the standing rules this notice rewrites.

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