Treasury Eyes Clarity For Passive Foreign Investment Cos.

Law360 (July 10, 2019, 7:31 PM EDT) -- The U.S. Treasury Department has proposed regulations that aim to clear up ambiguities under the tax regime for passive foreign investment companies, including guidance that addresses long-standing uncertainties in addition to a newly narrowed exception for offshore insurance companies.

The proposed rules provide guidance for issues that aren’t specifically addressed in current regulations and “resolve some of the complexities” that arise in determining U.S. ownership of a passive foreign investment company, or PFIC, according to Treasury. In addition, the regulations clarify how U.S. shareholders with stock in offshore insurance companies can determine whether those businesses qualify for an exception that was...

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