Data / Federal rules / 2025-19625
Domestically Controlled Qualified Investment Entities
The Internal Revenue Service published this proposed rule in the Federal Register on October 21, 2025. Comments closed on December 22, 2025.
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What the agency says
This document contains proposed regulations that would modify existing regulations on the determination of whether a qualified investment entity is domestically controlled by removing a rule that looks to the shareholders of certain domestic corporations in determining whether foreign persons hold directly or indirectly stock in a qualified investment entity. The proposed regulations would primarily affect foreign persons that own stock in a qualified investment entity that would be a United States real property interest if the qualified investment entity were not domestically controlled.
Key facts
- Document number
- 2025-19625
- Type
- Proposed rule
- Action
- Notice of proposed rulemaking
- Agency
- Treasury Department; Internal Revenue Service
- Published
- October 21, 2025
- Comments due
- December 22, 2025
- Dates
- Written or electronic comments and requests for a public hearing must be received by December 22, 2025.
- Docket
- REG-109742-25
- Regulation ID (RIN)
- 1545-BR60
- Code of Federal Regulations
- 26 CFR 1
- Topics
- Income taxes; Reporting and recordkeeping requirements
- Pages
- 5
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