(Archived Content)
FROM THE OFFICE OF PUBLIC AFFAIRS
To view or print the PDF content on this page, download the free Adobe® Acrobat® Reader®.
js-1494
Today, the Treasury Department published final regulations providing guidance for taxpayers that elect to mark to market stock of a passive foreign investment company. Passive foreign investment companies, or PFICs, are foreign corporations that predominantly earn, or hold assets that produce, passive or investment-type income, such as foreign mutual funds. The final regulations provide operating rules for making the mark to market election and for making determinations with respect to the annual mark to market inclusions. The final regulations also provide for the coordination of the mark to market regime with the rules that apply to PFICs generally.
The final regulations generally follow the proposed regulations, which were published in July of 2002, with some modest modifications in response to comments from taxpayers. The final regulations are effective for taxable years beginning after December 31, 2004.
The text of the final regulations is attached and will be on file tomorrow at the Federal Register.
-30-
REPORTS