U.S. Tax Review: Final Subpart F and Proposed PFIC Regs
In this installment of U.S. Tax Review, Larissa Neumann and Julia Ushakova-Stein examine final regulations on the treatment of the ownership of foreign corporations by domestic partnerships and their partners; proposed regulations on PFICs; the revised schedules K-2 and K-3 FAQ; and a NYSBA report on the application of section 382 to foreign corporations that undergo an ownership change.
Read the full commentary and analysis on Tax Notes, and read more insights on fenwick.com.