Par. 2. Section 1.892-2 is added to read as follows:
(a) Foreign government —(1) Definition. For further guidance, see § 1.892-2T(a)(1).
(2) Integral part. For further guidance, see § 1.892-2T(a)(2).
(3) Controlled entity. For further guidance, see § 1.892-2T(a)(3).
(4) Exceptions. A controlled entity, within the meaning of paragraph (a)(3) of this section, does not include any partnership for Federal tax purposes. A controlled entity also does not include any entity owned and controlled by more than one foreign sovereign. Thus, a foreign entity organized and wholly owned and controlled by multiple foreign sovereigns to invest jointly, or to foster economic, financial, and/or technical cooperation, is not a controlled entity for purposes of paragraph (a)(3) of this section.
(b) Inurement to the benefit of private persons. For further guidance, see § 1.892-2T(b).
(1) through (2) [Reserved]
(c) Pension trusts —(1) In general. For further guidance, see § 1.892-2T(c)(1) introductory text through (c)(1)(iv).
(i) through (v) [Reserved]
(2) Illustrations. For further guidance, see § 1.892-2T(c)(2).
(d) Political subdivision and transnational entity. For further guidance, see § 1.892-2T(d).
(e) Applicability date. Paragraph (a)(4) of this section applies to taxable years beginning on or after [DATE OF PUBLICATION OF FINAL RULE]. However, a foreign government within the meaning of §§ 1.892-2 and 1.892-2T may choose to apply paragraph (a)(4) of this section to a taxable year of its directly or indirectly wholly-owned entities beginning before [DATE OF PUBLICATION OF FINAL RULE] if the period of limitations on assessment of the taxable year is open under section 6501, and provided that the foreign government consistently applies the rule in its entirety to the taxable year and all succeeding taxable years of its directly or indirectly wholly-owned entities beginning before [DATE OF PUBLICATION OF FINAL RULE].