Deloitte has published their Tax News & Views which looks at new guidance on domestic passthrough entities owning stock in foreign corporations. The abstract is as follows:
The Treasury Department and the Internal Revenue Service released final regulations (T.D. 9960) and proposed regulations (REG-118250-20) on January 24 that address a variety of issues relating to the treatment of domestic partnerships and other passthrough entities that own stock in foreign corporations. Among those issues are the determination of subpart F income and section 956 inclusions, the identification of controlling domestic shareholders of a foreign corporation and of the owner of a controlled foreign corporation or qualified electing fund (QEF) for net investment income tax election purposes, and the application of the passive foreign investment company QEF and mark-to-market regimes.
The regulations also cover the treatment of S corporations with accumulated earnings and profits attributable to subpart F income and GILTI and the determination and inclusion of related-person insurance income under section 953(c).
Click here to read the full article: “Tax News & Views”
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.
Wealth Strategies Journal 