Voglio sapere a riguardo di…

13648

Federal Register / Vol. 86, No. 45 / Wednesday, March 10, 2021 / Rules and Regulations
Authority: 26 U.S.C. 7805

Par. 2. Section 1.12970 is amended by revising the entry for 1.1297
2g12 to read as follows:

1.12970

Table of contents.

1.12972 Special rules regarding lookthrough subsidiaries and look-through partnerships.

g
12 TFC obligation.

Par. 3. Section 1.12971 is amended by:
a. Removing 1.12972b2i in the first sentence of paragraph d1vC1 and adding in its place 1.12972b2i.
b. Revising paragraph f8.
The revision reads as follows:
1.12971 Definition of passive foreign investment company.

f
8 Related person. For purposes of applying the rules of this section and 1.12972 with respect to section 1297b2C, the term means a related person within the meaning of section 954d3.

Par. 4. Section 1.12972 is amended by:
a. Removing of this section in the first sentence of paragraph b3i and adding in its place of this section.
b. Revising the first sentence of paragraph c4iiiB.
c. Removing PFIC . at the end of paragraph e3iB1 and adding in its place PFIC.
d. Revising the first sentence of paragraph g4ivA2iii.
The revisions read as follows:
1.12972 Special rules regarding lookthrough subsidiaries and look-through partnerships.

c
4
iii
B The results are the same as in paragraph c4iiB of this section the results in Example 2, except that TFCs assets also do not include the stock of LTS2.

g
4
iv
A
2
iii For purposes of paragraph b3 of this section, FPS qualifies as a
VerDate Sep<11>2014

16:13 Mar 09, 2021

Jkt 253001

look-through partnership because TFC
satisfies the active partner tests of both paragraphs g4iiA and B of this section.

Par. 5. Section 1.12974 is amended by:
a. Revising paragraph d6.
b. Removing written by a in paragraph f5 and adding in its place written by, a.
The revision reads as follows:
1.12974 Qualifying insurance corporation.

d
6 Stock ownership. For purposes of this section, ownership of stock in a foreign corporation means either direct ownership of such stock or indirect ownership determined using the rules specified in 1.12911b8 but without regard to the 50 percent ownership requirement of 1.1291
1b8iiA.

Par. 6. Section 1.12982 is amended by revising the second sentence of paragraph c3, the second sentence of paragraph f1iB, and the first sentence of paragraph f2ii to read as follows:
1.12982 Rules for certain corporations changing businesses.

c
3 However, if activities performed by the officers and employees of a look-through subsidiary of a corporation or of a look-through partnership including a look-through subsidiary or a look-through partnership with respect to which paragraph d of this section applies would be taken into account by the corporation pursuant to 1.12972e if it applied, such activities are taken into account for purposes of the determination of the existence of an active trade or business and the determination of whether assets are used in an active trade or business.

f
1
i
B The residual gain computed under 1.12972f2 on the sale of the FS stock is $10x.

2
ii The results are the same as in paragraph f1ii of this section the results in Example 1, except that under paragraph c1 of this section, the passive income considered attributable to proceeds from a disposition of one or
PO 00000

Frm 00020

Fmt 4700

Sfmt 4700

more active trades or businesses is $4x from investment of disposition proceeds.

1.12984

Amended
Par. 7. Section 1.12984f is amended by removing Janyuary and adding in its place January.

Crystal Pemberton, Senior Federal Register Liaison, Legal Processing Division, Associate Chief Counsel Procedure and Administration.
FR Doc. 202104789 Filed 3921; 8:45 am BILLING CODE 483001P

DEPARTMENT OF THE TREASURY
Internal Revenue Service 26 CFR Part 1
TD 9936
RIN 1545BO59

Guidance on Passive Foreign Investment Companies; Correction Internal Revenue Service IRS, Treasury.
ACTION: Final regulations; correction.
AGENCY:

This document contains corrections to the final regulations Treasury Decision 9936, that were published in the Federal Register on Friday, January 15, 2021. The final 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, and the application and scope of certain rules that determine whether a United States person that indirectly holds stock in a PFIC is treated as a shareholder of the PFIC.
DATES: These corrections are effective on March 10, 2021 and applicable on or after January 15, 2021.
FOR FURTHER INFORMATION CONTACT:
Concerning the regulations 1.12910
and 1.12911, 1.12970 through 1.1297
2, 1.12980, 1.12982, and 1.12984, Christina G. Daniels at 202 3176934;
concerning the regulations 1.12974
and 1.12976, Josephine Firehock at 202 3174932 not toll-free numbers.
SUPPLEMENTARY INFORMATION:
SUMMARY:

Background The final regulations TD 9936 that are the subject of this correction are issued under sections 1297 and 1298 of the Internal Revenue Code.

E:FRFM10MRR1.SGM

10MRR1