Domestically Controlled Qualified Investment Entities

Key Points

• 1The IRS is creating clearer definitions for investment entities that are controlled by U.S. owners to qualify for specific tax benefits
• 2This rule primarily affects investment fund managers, partnerships, and financial institutions that manage money for investors
• 3The regulation determines tax treatment based on domestic control and ownership, which can impact how much tax investors and fund managers owe
• 4This is a proposed rule, so the public has until December 23, 2025 to submit comments before the IRS makes it final
• 5The rule helps prevent foreign investors from getting tax advantages intended only for domestically-owned investments

Key Dates