New Guidance Regarding Ownership of Passive Foreign Investment Companies

摘要

The Internal Revenue Service and Treasury Department have issued temporary and final regulations providing guidance on the ownership of "passive foreign investment companies" and implementing an annual reporting requirement for shareholders of such companies. The regulations, which replace and expand certain provisions of regulations that had been proposed over two decades ago, are effective as of December 30, 2013-the day they were issued. This article describes and analyzes those regulations.