The U.S. Department of the Treasury and the Internal Revenue Service on July 10, 2019, released proposed regulations relating to the tax treatment of investors that own stock of a passive foreign investment company (“PFIC”)...more
After an initial period of almost 30 years without significant regulatory guidance addressing the statutory exception for foreign insurance companies under the passive foreign investment company (PFIC) regime, the U.S....more
On April 23, Treasury and the IRS issued proposed regulations interpreting the active insurance exception under the passive foreign investment company (PFIC) rules. Although the release of the proposed regulations did not...more