Treasury Department Proposed Rule

2022-00067: Guidance on Passive Foreign Investment Companies and Controlled Foreign Corporations Held by Domestic Partnerships and S Corporations and Related Person Insurance Income

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Summary

This document contains proposed regulations regarding the treatment of domestic partnerships and S corporations that own stock of passive foreign investment companies ("PFICs") and their domestic partners and shareholders (the "proposed regulations"). The proposed regulations also provide guidance regarding the determination of the controlling domestic shareholders of foreign corporations, the owner of a controlled foreign corporation ("CFC") or qualified electing fund ("QEF") that makes an election under section 1411, the treatment of S corporations with accumulated earnings and profits under subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code ("subpart F" of the "Code"), and the determination and inclusion of related person insurance income ("RPII") under section 953(c). The proposed regulations affect United States persons that own, directly or indirectly, stock in certain foreign corporations.

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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