Managing Director Joe Calianno's comments were included in the recent Tax Notes article, New PFIC Rules Favor Aggregate Approach to Partnerships.New proposed rules on passive foreign investment companies (PFICs) recently released by IRS pivot from entity treatment of domestic partnerships to an aggregate approach. Calianno noted that there appeared to be real movement by IRS to conform to a more aggregate approach for partnerships.

Joe Calianno is a Managing Director in the US National Tax practice in the Washington D.C. office. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act and cross-border restructuring.

January 25, 2022

Tax Notes

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