DEPARTMENT OF THE TREASURY Internal Revenue Service

[4830-01-p] DEPARTMENT OF THE TREASURYI nternal Revenue Service26 CFR Part 1[REG-118250-20]RIN 1545-BP94 Guidance on Passive Foreign Investment Companies and Controlled Foreign Corporations Held by Domestic Partnerships and S Corporations and Related Person Insurance IncomeAGENCY: Internal Revenue Service (IRS), : Notice of proposed rulemaking and partial withdrawal of notice of proposed : This document contains proposed regulations regarding the treatment of domestic partnerships and S corporations that own stock of passive foreign investment companies ( PFICs ) and their domestic partners and shareholders (the proposed regulations ). The proposed regulations also provide guidance regarding the determination of the controlling domestic shareholders of foreign corporations, the owner of a controlled foreign corporation ( CFC ) or qualified electing fund ( QEF ) that makes an election under section 1411, the treatment of S corporations with accumulated earnings and profits under subpart F of part III of subchapter N o

instructions for submitting comments. Once submitted to the Federal eRulemaking Portal, comments cannot be edited or withdrawn. The IRS expects to have limited personnel available to process public comments that are submitted on paper through mail. Until further notice, any comments submitted on paper will be considered to the extent practicable.

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