Article
IRS And Treasury Propose Revised Applicability Dates For Section 892 Rules On Foreign Government Investments
The IRS and Treasury have released new proposed regulations under Section 892, revising applicability dates for previously proposed rules from 2025 that govern debt acquisitions and the "effective control" standard for foreign government investments. These revised dates include transition rules designed to protect existing and committed investments from the more stringent 2025 standards, while the preamble signals potential substantive changes to address market concerns.
Skadden Arps Slate Meagher & Flom