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
…rovided in the final regulations.
C. Clarification With Respect to the Applicability of the Section 897(l) Regulations These regulations reflect the particular policies and objectives underlying section 897(l) (as opposed to other areas of tax law that relate to pension funds). To clarify this, § 1.897(l)-1(a) provides…
84 FR 26605 — Exception for Interests Held by Foreign Pension Funds IRCProposed Rules (FR)Proposed Jun 7, 2019
ection 897(h) occurring on or after the date of publication of the Treasury decision adopting these rules as final regulations in the
Federal Register . However, proposed §§ 1.897(l)-1(b)(1), 1.897(l)-1(d)(5), 1.897(l)-1(d)(7), 1.897(l)-1(d)(9), 1.897(l)-1(d)(11), and 1.897(l)-1(d)(14) are proposed to apply with respec…
ERISARegulationsApr 8, 2024related by meaning
(a) (a) Explain the exemption transaction and summarize the information and reasons in support of proposing the exemption;
ERISARegulationsJan 1, 2017related by meaning
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PBGCRegulationsDec 7, 2023related by meaning
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