EYUS final regulations treat domestic partnerships as aggregates for applying certain subpart F provisions, and proposed regulations would apply a similar approach to PFICs
|Tax Alerts, National/Federal Taxation, L ...|United States
On 25 January 2022, the United States (US) Treasury Department and the Internal Revenue Service (IRS) published final regulations (T.D. 9960) treating domestic partnerships as aggregates (i.e., not as entities) for many subpart F purposes. These regulations finalize, with limited changes, regulations originally proposed in 2019 (See EY Global Tax Alerts, US final and proposed GILTI and subpart F r…
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