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Passive Foreign Investment Company Rules: Treatment of Income from Certain Government Bonds for Purposes of the Passive Foreign Investment Company Rules by Theodore D. Holt Sullivan & Cromwell LLP - New York Office
Donald L. Korb Sullivan & Cromwell LLP - New York Office
Dexter D.J. Samida Sullivan & Cromwell LLP - New York Office
Andrew P. Solomon Sullivan & Cromwell LLP - London Office
David C. Spitzer Sullivan & Cromwell LLP - New York Office
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July 5, 2012
Previously published on July 2, 2012
In an important notice responding to current economic conditions, the Internal Revenue Service has acknowledged that banks may be holding larger amounts of government securities than they ordinarily would, and that it does not intend this situation to cause them to be treated as “passive foreign investment companies,” a category that may discourage U.S. persons from investing in their shares.
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