Old Law, New Tricks: Long-Awaited PFIC Guidance Proposed
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. [...]Read more