On November 3, 2011, the IRS published proposed regulations under Section 892 of the Code that provide helpful guidance, and answer several questions, regarding the extent to which a foreign sovereign, a sovereign wealth fund or other controlled entities will be exempt from US tax under Section 892 of the Code on their investments into the United States. The proposed regulations have significant implications, particularly for sovereign wealth funds, in how they structure their investments into the United States. Pending finalization, the IRS has indicated that taxpayers may rely on the proposed regulations.
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