87 FR 80097 — Guidance on the Foreign Government Income Exemption and the Definition of Domestically Controlled Qualified Investment Entities IRCProposed Rules (FR)Proposed Dec 29, 2022
… foreign pension funds and qualified controlled entities as foreign persons for purposes of section 897(h)(4)(B). (l) * * * For purposes of sections 897 and 6039C, however, the term does not include a foreign corporation with respect to which there is in effect an election under section 897(i) and § 1.897-3 to be treat…
89 FR 31618 — Guidance on the Definition of Domestically Controlled Qualified Investment Entities IRCFinal Rules (FR)Apr 25, 2024★ strong match
… April 25, 2024,
see
paragraphs (c)(2)(i) and (l) of this section and § 1.897-9T(c) contained in 26 CFR part 1, as revised April 1, 2024.
* * * * *
(c) * * *
(3)
Domestically controlled QIE—
(i)
In general.
87 FR 80042 — Exception for Interests Held by Foreign Pension Funds IRCFinal Rules (FR)Dec 29, 2022★ strong match
uired by proposed § 1.897(l)-1(c)(iv)(B), or such information is otherwise available, to one or more governmental units. Prop. § 1.897(l)-1(c)(iv)(C). One comment highlighted that the rules in the proposed regulations are inadvertently inconsistent when an eligible fund is required by foreign law to provide information…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019★ strong match
…the IRS requested comments regarding what regulations, if any, should be issued pursuant to section 897(l)(3). Twenty-one comments were received, requesting, in particular, guidance on issues related to qualification as a “qualified foreign pension fund” under section 897(l)(2). The comments will be included in the adm…
ERISARegulationsJan 1, 2017related by meaning
(l) (l) Person includes an individual, partnership, corporation, employee benefit plan, association, exchange or other entity or organization;
ERISARegulationsJan 1, 2017related by meaning
For section 502(c)(6) civil penalty proceedings, this section shall apply in lieu of the definitions in § 18.2 of this title:
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ERISARegulationsJan 1, 2017related by meaning
For purposes of this section:
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