Guidance on Passive Foreign Investment Companies and the Treatment of Qualified Improvement Property Under the Alternative Depreciation System for Purposes of Sections 250(b) and 951A(d); Correction

摘要

This document contains a correction to a notice of proposed rulemaking (REG-111950-20) that was published in the Federal Register on January 15, 2021. The proposed regulations regarding the determination of whether a foreign corporation is treated as a passive foreign investment company ("PFIC") for purposes of the Internal Revenue Code ("Code").