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20 October 2025

Proposed regulations would remove domestic corporation look-through rule for determining qualified investment entity control

The Treasury Department and IRS on October 20, 2025, released proposed regulations (REG-109742-25) that would remove the domestic corporation look-through rule, which was finalized in 2024, for determining domestic control of a qualified investment entity (QIE) (see Tax Alert 2024-0885). The proposed regulations would treat all domestic C corporations as non-look-through persons for purposes of IRC Section 897(h)(4)(B) and provide conforming amendments to Treas. Reg. Section 1.897-1(c)(3). A Tax Alert is forthcoming.

Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2025-2112

 

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