SECTION 2. BACKGROUND
Internal Revenue Bulletin 2014-20 · 2026-10-03 edition · updated 2026-10-04 · United States
Recent economic conditions have resulted in a shift in the assets held by some non-U.S. financial institutions. As a result of these conditions, certain non-U.S. financial institutions continue to hold government bonds at higher than historical levels. These increased levels raise an issue concerning the treatment of these financial institutions, and specifically the treatment of government bonds, under the PFIC rules.
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