Title

New Guidance Regarding Ownership of Passive Foreign Investment Companies.

Authors

Solomon, Andrew P.; Spitzer, David C.; Wang, Davis J.; Wheeler, Isaac J.; Wang, S. Eric

Abstract

The Internal Revenue Service and Treasury Department have issued temporary and final regulations providing guidance on the ownership of "passive foreign investment companies" and implementing an annual reporting requirement for shareholders of such companies. The regulations, which replace and expand certain provisions of regulations that had been proposed over two decades ago, are effective as of December 30, 2013--the day they were issued. This article describes and analyzes those regulations.

Subjects

UNITED States; PASSIVE foreign investment companies; GOVERNMENT policy; UNITED States. Internal Revenue Service; UNITED States. Dept. of the Treasury; FOREIGN corporation laws; LEGAL status of stockholders

Publication

Journal of Taxation of Investments, 2014, Vol 31, Issue 3, p43

ISSN

0747-9115

Publication type

Academic Journal