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To print this article, all you need is to be registered or login on Mondaq.com. IRS Issues Final PFIC Ownership Regulations The IRS has issued final regulations (TD 9936) regarding how to determine if a foreign corporation is a passive foreign investment company (PFIC) and the application and scope of certain rules that determine whether a U.S. person that indirectly holds stock in a PFIC is treated as a shareholder of the PFIC. On July 11, 2019, the IRS published proposed regulations (REG-105474-18) under Sections 1291, 1297, and 1298 (see our prior coverage  here)...