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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Suggestion For You:
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
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