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The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances. On the same date, the IRS and Treasury also finalized previously
proposed regulations that “look through” domestic
partnerships when determining a controlled foreign
corporation’s 10% U.S. shareholders, instead of calculating
percentage ownership at the partnership level. POPULAR ARTICLES ON: Finance and Banking from United States
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On January 25, 2022, the IRS and Treasury proposed regulations
that would treat U.S. partners, instead of their partnerships, as
PFIC shareholders for making qualified electing fund,
mark-to-market, or purging elections, recognizing QEF or MTM
income, applying the controlled foreign corporation overlap rule,
and filing Forms 8621 (PFIC information returns). Partners would be
required to notify the partnership of their election. The proposed
regulations would apply from the date they are finalized, and would
not nullify previous partnership-level elections.
Cadwalader, Wickersham & Taft LLP
It’s The End Of LIBOR As We Know It Cadwalader, Wickersham & Taft LLP The Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Department of the Treasury (“Treasury”) has made clear that businesses engaging in certain activities involving virtual currencies are subject to registration, reporting, recordkeeping, and other anti-money laundering (“AML”) requirements under the Bank Secrecy Act and its implementing regulations.
Torres Law, PLLC FinCEN Crypto & Ransomware Guidance: Will 2022 Bring More Changes?
The News Highlights
- Proposed regulations affect PFIC elections – Finance and Banks
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