KPMG report: Final and proposed regulations, passive foreign investment company (PFIC) rules

Passive foreign investment company (PFIC) rules

Final regulations (T.D. 9936) and proposed regulations (REG-111950-20) concerning passive foreign investment company (“PFIC”) rules are published in today’s edition of the Federal Register.

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The proposed regulations also contain rules related to qualified business asset investment (QBAI) announced in Notice 2020-69.


Read a January 2021 report [PDF 6.4 MB] prepared by KPMG LLP that provides initial impressions and observations about the regulations.

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