Prop. Treas. Reg. § 1.1411-10 Controlled foreign corporations and passive foreign investment companies.

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 1411 · Would amend § 1.1411-10

Par. 36. Section 1.1411-10 is amended by adding a sentence at the end of paragraph (c)(1)(i)(A)( 1 ) to read as follows:

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(c) * * *

(1) * * *

(i) * * *

(A) * * *

( 1 ) * * * See section 959 and the regulations in this part issued under section 959 for rules regarding previously taxed earnings and profits, including previously taxed earnings and profits assigned to the taxable section 1411 PTEP subgroup (as defined in § 1.959-2(b)(2)(ii)(A)).

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