New Rules Address Reporting Obligations of US Shareholders in
Foreign Funds and Certain Other Foreign Corporations
On December 30, 2013, the US Treasury Department (the
"IRS") published a package of proposed, temporary, and
final regulations relating to Passive Foreign Investment Companies
("PFICs") and their shareholders. The most significant
component of the package is its guidance on the new annual filing
requirements for PFIC shareholders, but the package also includes
other, generally minor, changes to existing rules governing PFICs
and their shareholders.
The IRS issued the regulations just in time to meet a
self-imposed year-end deadline: the IRS wanted the new reporting
rules to become effective before 2013 ended so that the new
reporting rules would apply during the next filing season. Still,
the package includes good news for some PFIC shareholders since the
new regulations eliminate a retroactive filing requirement for 2011
and 2012 taxable years that
