Date: 2022-01-25
Links to Federal Register: HTML, PDF
Document Number: 2022-00067, RIN: 1545-BP94
Action: Notice of proposed rulemaking and partial withdrawal of notice of proposed rulemaking.
Abstract: 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 of chapter 1 of the Internal Revenue Code ("subpart F" of the "Code"), and the determination and inclusion of related person insurance income ("RPII") under section 953(c). The proposed regulations affect United States persons that own, directly or indirectly, stock in certain foreign corporations.
| Notable phrases | Frequency |
|---|---|
| united states person(s) | 40 |
| earnings and profits | 28 |
| domestic nongrantor trust | 27 |
| treated as owning | 25 |
| domestic partnerships (and|or) s corporation(s) | 21 |
| controlling domestic shareholders | 20 |
| related person insurance | 18 |
| stock of a pfic | 17 |
| pro rata share | 17 |
| accumulated earnings and profits | 15 |
| years of foreign corporations | 14 |
| years of shareholders | 13 |
| Reg. Cites | Frequency |
|---|---|
| 1.1291-1(b)(7) | 24 |
| 1.1295-1(d)(2)(i)(A) | 11 |
| 1.1298-1(b)(1) | 10 |
| 1.1295-1 | 9 |
| 1.958-1(e) | 9 |
| 1.958-1(d)(1) | 9 |
| 1.1293-1(c)(1) | 8 |
| 1.1296-1(h)(1)(i) | 8 |
| 1.1298-3 | 8 |
| 1.1298-1 | 8 |
| 1.1297-3 | 8 |
| 1.1296-1 | 8 |
| 1.953-3 | 7 |
| 1.964-1(c)(3)(ii) | 7 |
| 1.951A-5 | 7 |
| 1.1411-10(g) | 5 |
| 1.964-1 | 5 |
| 1.951A-1(e)(2)(iii) | 5 |
| 1.958-1(d) | 5 |
| 1.964-1(c) | 5 |
| Sec. Cites | Frequency |
|---|---|
| 1295 | 59 |
| 951A | 42 |
| 951 | 31 |
| 1296 | 28 |
| 1297(d) | 22 |
| 958(a) | 19 |
| 1291 | 19 |
| 1297(e) | 17 |
| 958(a) | 15 |
| 953(c) | 9 |
| 1298(f) | 9 |
| 902 | 7 |
| 1411 | 6 |
| 1298(a) | 5 |
| 964(a) | 5 |
| 953(c)(2) | 5 |
| 953 | 5 |
| 951(b) | 4 |
| 1297(d)(2) | 4 |
Statistics
Number of pages: 30, words: 32,723, sentences: 1,001
Average words per sentence: 32