Old Law, New Tricks: Long-Awaited PFIC Guidance Proposed

Written by and

Our International Tax Group highlights new guidance on fundamental issues and points out a few sources of potential headache for taxpayers in response to the IRS and Treasury proposing the most significant regulations on passive foreign investment companies (PFICs) in nearly 30 years.

  • Clarifications for the Income and Asset Tests
  • Updates to the PFIC exceptions and look-through rules
  • PFIC stock attribution

Read the full advisory here.