Date: 2025-10-21
Links to Federal Register: HTML, PDF
Document Number: 2025-19625, RIN: 1545-BR60
Action: Notice of proposed rulemaking.
Abstract: This document contains proposed regulations that would modify existing regulations on the determination of whether a qualified investment entity is domestically controlled by removing a rule that looks to the shareholders of certain domestic corporations in determining whether foreign persons hold directly or indirectly stock in a qualified investment entity. The proposed regulations would primarily affect foreign persons that own stock in a qualified investment entity that would be a United States real property interest if the qualified investment entity were not domestically controlled.
| Notable phrases | Frequency |
|---|---|
| directly or indirectly | 34 |
| foreign person(s) | 26 |
| non-look-through person(s) | 24 |
| domestically controlled qie | 18 |
| look-through rule | 15 |
| nonresident alien individual(s) | 12 |
| domestic c corporation(s) | 10 |
| less than 50 percent | 6 |
| qualified investment entit(y|ies) | 6 |
| united states person(s) | 6 |
| less than five-percent | 4 |
| considered as held | 4 |
| united states real property | 4 |
| qualified foreign pension(s) | 4 |
| u.s. citizen partner(s) | 4 |
| united states real property interest(s) | 3 |
| Reg. Cites | Frequency |
|---|---|
| 1.1445-2(c)(3) | 3 |
| 301.7701-3 | 3 |
| 1.897-1(c)(3) | 2 |
| 1.897-1 | 2 |
| 1.897-1(c)(3)(vi) | 1 |
| 1.897-1(c)(3)(iii)(b) | 1 |
| 1.897-2(h) | 1 |
| 1.897-2 | 1 |
| 1.897-4 | 1 |
| 1.897-9T(c) | 1 |
| Sec. Cites | Frequency |
|---|---|
| 897(h)(4)(b) | 6 |
| 897(h)(4)(e) | 3 |
| 7805(f) | 2 |
| 897(c)(1)(a)(ii) | 1 |
| 871(b)(1) | 1 |
| 882(a)(1) | 1 |
| 897(c)(1)(a) | 1 |
| 897(a)(1) | 1 |
| 897(c)(3) | 1 |
| 897(h)(4)(a) | 1 |
| 897(h)(1) | 1 |
| 897(c)(2) | 1 |
| 897(h)(4)(d) | 1 |
| 897) | 1 |
| 897(a) | 1 |
| 897(h)(2) | 1 |
| 897 | 1 |
| 1445 | 1 |
Statistics
Number of pages: 5, words: 5,120, sentences: 155
Average words per sentence: 33