SECTION 1. PURPOSE

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) will amend the regulations under section 1291 of the Internal Revenue Code (Code) to provide guidance concerning the treatment of United States persons (U.S. persons) that own stock of a passive foreign investment company within the meaning of section 1297(a) (PFIC) through: an organization or an account that is exempt from tax under section 501(a) because it is described in section 501(c), 501(d), or 401(a); a state college or university described in section 511(a)(2)(B); a plan described in section 403(b) or 457(b); an individual retirement plan or annuity as defined in section 7701(a)(37); or a qualified tuition program described in section 529 or 530.