On April 25, 2022, Eminence submitted a comment letter to the Treasury Department and Internal Revenue Service (IRS) in response to its proposed PFIC regulations. Eminence emphasizes that the proposed regulations introduce a substantial compliance burden on taxpayers and partnerships that invest in foreign corporations, without any notable benefit to tax compliance, administration, and enforcement.
Eminence’s comment letter stresses that the preferences of alternative investment funds and their investors are aligned in making certain elections in respect of foreign corporations in which they are invested, and that investors uniformly prefer for fund managers to service the compliance burden associated with those investments. Eminence’s comment letter advocates for the ability of investors to delegate the authority to make elections and file returns to fund managers on their behalf.
Eminence also joined several other industry associations as a signatory to a comment letter which voices similar concerns. Click here to view the joint letter.
