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What?! Me, Change? Proposed Regs Under 951A Adopt Aggregate Approach and Make Definite Changes to PFIC Reporting

February 08, 2022

The Treasury and IRS issued proposed regulations under I.R.C. Section 951A providing guidance on passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs) held by domestic partnerships and S corporations. 87 Fed. Reg.  3,890 (Jan. 25, 2022). The proposed rules impact PFIC reporting and determine that domestic partnerships and S corporations should be treated as entities or aggregates of their partners and shareholders, respectively, for purposes of making qualified electing fund (QEF) or mark-to-market (MTM) elections, recognizing QEF inclusions or MTM amounts, or filing Forms 8621.


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