IRS Updates Passive Foreign Investment Reporting Rules

Law360, New York (January 2, 2014, 1:10 PM EST) -- The Internal Revenue Service issued temporary regulations on Tuesday addressing annual filing requirements for U.S. shareholders in passive foreign investment companies and clarifying PFIC stock ownership rules for partners, shareholders and beneficiaries in partnerships, S corporations, estates and trusts.

The IRS and U.S. Department of the Treasury had suspended annual filing requirements for certain PFIC shareholders from March 2010 onward, but Tuesday's regulations reinstate the filing requirement for taxable years ending on Dec. 31 and afterward, and also clarify that stock attribution rules that apply to...
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