The Resource IRS revisits application of the PFIC domestic stock and subsidiary look-through rule

IRS revisits application of the PFIC domestic stock and subsidiary look-through rule

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IRS revisits application of the PFIC domestic stock and subsidiary look-through rule
Title
IRS revisits application of the PFIC domestic stock and subsidiary look-through rule
Creator
Subject
Language
eng
Summary
In the November-December 2013 edition of this journal, the authors published an article discussing LTR 201322009 (the 2013 LTR). In the 2013 LTR, the IRS addressed, for the first time, the application of the Code Sec. 1298(b)(7) look-through rule (Domestic Stock Rule) to a foreign corporation's potential status as a passive foreign investment company (PFIC). The rulings granted by the 2013 LTR provided useful insight on several ambiguous aspects of Code Sec. 1298(b)(7). The IRS recently released another private letter ruling, LTR 201515006 (the 2015 LTR) that addresses the PFIC testing and look-through rules in a similar case. As discussed in this article, the 2015 LTR suggests that the IRS may have had some reservations about the 2013 LTR. More importantly, however, the 2015 LTR appears to be the first time that the IRS has affirmatively approved certain applications of the general Code Sec. 1297(c) PFIC 'Subsidiary Look-Through Rule' that were clearly contemplated by Congress, but not heretofore addressed by government guidance. This article provides a brief summary of the relevant PFIC rules, a review of the 2013 LTR and then a more detailed examination of the 2015 LTR
Citation source
In: International tax journal. - Chicago. - Vol. 41 (2015),
http://library.link/vocab/creatorName
  • Cornett, J.M
  • Holland, D. (Douglas)
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • private ruling
  • passive foreign investment company
  • looking through
Label
IRS revisits application of the PFIC domestic stock and subsidiary look-through rule
Instantiates
Publication
Label
IRS revisits application of the PFIC domestic stock and subsidiary look-through rule
Publication

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