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.


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.

© 2022 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.

For more detail about the structure of the KPMG global organization please visit

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us