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Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement).This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements.These temporary and final regulations provide guidance on determining the ownership of a passive foreign investment company, the annual filing requirements for shareholders of PFICs, and an exclusion from certain filing requirements for shareholders that constructively own interests in certain foreign corporations.This is a notice of proposed rulemaking by cross-reference to temporary regulations.Section 1298(f) requires a United States person that is a shareholder of a PFIC to file an annual report containing such information as the Secretary may require.

Section 1122(a) of the Taxpayer Relief Act added the MTM regime under section 1296 to the Code, and section 1121 of the Taxpayer Relief Act added section 1297(d).The revenue procedure also provides guidance to FFIs and branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA) (reporting Model 2 FFIs) on complying with the terms of an FFI agreement, as modified by the IGA.This notice confirms that tax-exempt hospitals can rely on proposed regulations under § 501(r) contained in notices of proposed rulemaking (NPRMs) issued on June 26, 2012, and April 5, 2013, pending the publication of final or temporary regulations or other applicable guidance.Section 1297(d) provides that, in certain situations, a PFIC that is also a controlled foreign corporation (“CFC”) is not treated as a PFIC with respect to certain shareholders.However, section 1298(a)(2)(B) provides that a foreign corporation that would, but for the rules of section 1297(d), be a PFIC is treated as a PFIC with respect to its shareholders for purposes of determining whether the shareholders own an interest in any PFIC held by the foreign corporation.

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  1. "Once we adjusted for the marine signature, all of the skeletons that showed definite signs of treponemal disease appeared to be dated to after Columbus returned to Europe," Harper said, findings detailed in the current Yearbook of Physical Anthropology.