The Internal Revenue Service plans to amend the regulations for the treatment of U.S. taxpayers who own passive foreign investment company stock through tax-exempt organizations.
In Notice 2014-28, the IRS said last week that it and the Treasury Department will amend the regulations under Section 1291 of the Tax Code to provide guidance concerning the treatment of U.S. persons that own stock of a passive foreign investment company through an organization or an account that is tax-exempt, including a state college or university, an individual retirement plan or annuity, or a qualified tuition program.
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