INCOME TAX

REG-118250-20, page 753. This document contains proposed regulations regarding the treatment of domestic partnerships and

Finding Lists begin on page ii.

S corporations that own stock of passive foreign investment companies and their domestic partners and shareholders. These proposed regulations also provide guidance regarding the determination of the controlling domestic shareholders of foreign corporations, the owner of a controlled foreign corporation or qualified electing fund that makes an election under section 1411, the treatment of S corporations with accumulated earnings and profits under subpart F of part III of subchapter N of chapter 1 of the Internal Revenue Code, and the determination and inclusion of related person insurance income under section 953(c). These proposed regulations affect United States persons that own, directly or indirectly, stock in certain foreign corporations.