# Prop. Treas. Reg. § 1.1291-9: [Amended]

Proposed regulation, not in force. REG-101828-19, 87 FR 3890, published 2022-01-25 <https://www.federalregister.gov/documents/2022/01/25/2022-00067/guidance-on-passive-foreign-investment-companies-and-controlled-foreign-corporations-held-by>. Interprets 26 U.S.C. § 1291.

Par. 8. Section 1.1291-9 is amended by: 1. Removing the language “the undistributed earnings and profits, within the meaning of section 902(c)(1)” in paragraph (a)(2)(i) and adding “the amount of the earnings and profits of the foreign corporation (computed in accordance with sections 964(a) and 986)” in its place; 2. Removing the language “section 1297(e) PFIC” in paragraphs (i) and (j)(2)(v) introductory text and adding “section 1297(d) PFIC” in its place wherever it appears; and 3. Removing the language “section 1297(e)(2)” in paragraph (j)(2)(v)(A) and adding “section 1297(d)(2)” in its place. Par. 9. Section 1.1293-1 is amended by: 1. Adding paragraphs (a)(3) and (4); 2. Revising paragraphs (c)(1) and (2); 3. Redesignating paragraph (c)(3) as paragraph (c)(4); 4. Adding a new paragraph (c)(3); and 5. Revising newly redesignated paragraph (c)(4). The additions and revisions read as follows: